January 29, 2020

Govinda Giri
Chief Executive Officer
Sagoon Inc.
1980 Teasel Ct.
Woodbridge, VA 22192

       Re: Sagoon Inc.
           Amendment No. 2 to Offering Statement on Form 1-A
           Filed January 22, 2020
           File No. 024-11120

Dear Mr. Giri:

       We have reviewed your amended offering statement and have the following
comment. In
our comment, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to this letter by amending your offering statement and
providing the
requested information. If you do not believe our comment applies to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your offering statement and the
information you
provide in response to this comment, we may have additional comments. Unless we
note
otherwise, our references to prior comments are to comments in our January 17,
2020 letter.

Amendment No. 2 to Offering Statement on Form 1-A

The Company's Business, page 18

1.    Your revised disclosure in response to the prior comment and to comment 3
of our letter
      dated December 12, 2019 does not quantify active users of your platform
for each period
      presented. As it appears that there is a measure of user activity that
you use in managing
      your business (e.g., average monthly active users), please provide such
information in
      addition to the registered user information that you provide, or advise.
In this regard, we
      note your statement that "[h]undreds of thousands of people visit your
site on a monthly
      basis."
 Govinda Giri
Sagoon Inc.
January 29, 2020
Page 2

        You may contact Ryan Rohn, Staff Accountant, at (202) 551-3739 or
Stephen Krikorian,
Accounting Branch Chief, at (202) 551-3488 if you have questions regarding
comments on the
financial statements and related matters. Please contact Bernard Nolan,
Attorney-Adviser, at
(202) 551-6515 or, in his absence, Jan Woo, Legal Branch Chief, at (202)
551-3453 with any
other questions.



                                                         Sincerely,
FirstName LastNameGovinda Giri
                                                         Division of
Corporation Finance
Comapany NameSagoon Inc.
                                                         Office of Technology
January 29, 2020 Page 2
cc:       Andrew Stephenson
FirstName LastName