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                             October 23, 2020

       Jason Drummond
       Chief Executive Officer
       Dito, Inc.
       413 West 14th Street
       New York, NY 10014

                                                        Re: Dito, Inc.
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Submitted October
9, 2020
                                                            CIK No. 0001816906

       Dear Mr. Drummond:

             We have reviewed your amended draft registration statement and
have the following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments. References to our prior comments refer to our letter dated
August 18, 2020.

       Amendment No. 1 to Registration Statement on Form S-1

       Business, page 38

   1.                                                   We note your responses
to prior comments 6 and 7 regarding the status and development
                                                        cycle of your software
platform. We note that you have no employees and one consultant.
                                                        Please clarify who
provided the software development work since you acquired the
                                                        Gametech assets in 2018
through Dito-UK and the administration proceeding. Further,
                                                        please clarify the
status of your software platform and how you expect to monetize the
                                                        software platform. It
is unclear whether the software platform is ready for market or if it
                                                        needs further
development to bring it to market.
 Jason Drummond
FirstName
Dito, Inc. LastNameJason Drummond
Comapany
October  23,NameDito,
             2020     Inc.
October
Page  2 23, 2020 Page 2
FirstName LastName
        You may contact Brittany Ebbertt, Senior Staff Accountant, at
202-551-3572 or Kathy
Collins, Accounting Branch Chief, at 202-551-3499 if you have questions
regarding comments
on the financial statements and related matters. Please contact Edwin Kim,
Attorney-Advisory, at
202-551-3297 or Jan Woo, Legal Branch Chief, at 202-551-3453 with any other
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Technology
cc:      Daniel D. Nauth, Esq.