United States securities and exchange commission logo





                               May 18, 2021

       Gagi Gogolashvili
       Chief Executive Officer
       Intorio, Corp.
       24 Alexander Kazbegi Ave
       Tbilisi 0177, Georgia

                                                        Re: Intorio, Corp.
                                                            Amended
Registration Statement on Form S-1
                                                            Filed May 6, 2021
                                                            File No. 333-255055

       Dear Mr. Gogolashvili:

             We have reviewed your amended 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 amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our May
3, 2021 letter.

       Amendment No.1 to Form S-1 filed May 6, 2021

       Cover Page

   1.                                                   We note your response
to prior comment 1. Please revise the cover page to specify the
                                                        percentage of issued
and outstanding shares owned by your directors and officers if 50%,
                                                        75%, or 100% of the
offering is sold. In this regard, it is not sufficient merely to disclose
                                                        that a majority of
shares will be held by your directors and officers.
       Dilution, page 15

   2.                                                   We reviewed your
revisions in response to prior comment 6. You have not subtracted
                                                        intangible assets from
your calculation of tangible book value. Please advise or revise.
 Gagi Gogolashvili
Intorio, Corp.
May 18, 2021
Page 2
Description of Our Business, page 18

3.       We note your response to prior comment 7 and re-issue the comment in
part. Please
         revise to describe whether you provide monthly or annual subscriptions
for your service.
         Also, please explain the number of lessons that an average student is
expected to complete
         and the cost per lesson. Lastly, please tell us whether you have
entered into any material
         agreements related to the launch of your business such as agreements
with service or
         technology providers. If so, please file the agreements as exhibits
with your next
         amendment and revise to describe their material terms.
4.       We note your response to prior comment 8 and re-issue. Please clarify
whether your
         "future clients" are students and parents, institutions (such as
school districts and
         universities), or otherwise. In this regard, we note that a tutoring
service could provide
         retail services to parents and students, in which case the parents and
students would be the
         clients. Alternatively, the tutoring service could enter into an
arrangement with a school
         district to provide tutoring services to all or some of the students
within the school district,
         in which case the school district itself would be the client. A
tutoring service could also
         offer its services via a hybrid method. Your disclosure should clearly
identify the parties
         with whom you will enter tutoring agreements and thus who your "future
clients" will be.
5.       We note your response to prior comment 9. Your disclosure remains
unclear as to which
         courses are currently available and which courses are merely
contemplated as future
         offerings. For example, in the third paragraph on page 18 we note your
disclosure on
         page 18 that you "plan to work . . . and provide" instruction in
certain subjects. With a
         view to providing your investors with information about the
development and status of
         your business operations, revise to clarify which subjects are
currently available. For
         those subjects which are available, state the grade levels currently
covered by your
         curriculum. If your curriculum is partial or incomplete, please also
disclose this fact.
        You may contact Tony Watson at (202) 551-3318 or Theresa Brillant at
(202) 551-3307
if you have questions regarding comments on the financial statements and
related
matters. Please contact Daniel Morris at (202) 551-3314 or Jacqueline Kaufman
at (202) 551-
3797 with any other questions.



FirstName LastNameGagi Gogolashvili                              Sincerely,
Comapany NameIntorio, Corp.
                                                                 Division of
Corporation Finance
May 18, 2021 Page 2                                              Office of
Trade & Services
FirstName LastName