United States securities and exchange commission logo





                             July 30, 2021

       Frank Magliochetti
       Chief Executive Officer
       ClickStream Corporation
       8549 Wilshire Boulevard Suite 2181
       Beverly Hills, CA 90211

                                                        Re: ClickStream
Corporation
                                                            Amendment No. 5 to
Offering Statement on Form 1-A
                                                            Filed July 22, 2021
                                                            File No. 024-11475

       Dear Mr. Magliochetti:

             We have reviewed your amended offering 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 offering 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 offering 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 July
12, 2021 letter.

       Amendment No. 5 to Form 1-A filed July 22, 2021

       Dilution, page 14

   1.                                                   Please provide us with
your calculation of the $1,921,000 net tangible book value of
                                                        March 31, 2021.
       Unaudited Interim Financial Statements
       Note 4. Note Receivable, Investment and Option to Acquire Common Shares
- Winners, Inc.
       C. Option to acquire common shares of Winners, Inc., page 57

   2.                                                   You state here that the
fair value of your investment in 500,000 shares of Winner's
                                                        common stock increased
to $297,000 resulting in a gain of $262,000 for the six months
                                                        ended March 31, 2021.
You also state here that the option to acquire common shares of
 Frank Magliochetti
ClickStream Corporation
July 30, 2021
Page 2
       Winners was accounted for at cost and the balance of $100,000 remained
unchanged at
       March 31, 2021. However, your disclosures on page 28 indicate that the
balance in
       Winners common stock and the option to acquire common shares of Winners
was $35,000
       and $362,000, respectively at March 31, 2021. Please explain this
apparent inconsistency
       and revise your disclosures as necessary. In your response, explain
further how you
       determined the fair value of the investment in Winners. Provide us with
your calculations
       to support the $262,000 gain and cite the specific accounting guidance
applied.
Note 5. Acquisition of Nebula Software Corp. (Asset Purchase), page 58

3.     In your response to comment 2 in your July 1, 2021 letter you state that
the company
       issued 5.0 million shares to both Chaudry, LLC and Lookash Realty
pursuant to the
       Reorganization and Stock Purchase Agreement with Nebula Software as a
result of the
       launch of the HeyPal app. Please revise here to include a discussion of
these additional
       shares and the related valuation.
General

4.     Wherever you disclose shares currently outstanding of 243,963,102,
revise to clarify
       whether this represents the shares outstanding as of the date of the
filing or or
       whether such amount reflects the shares outstanding as of the most
recent balance sheet
       date. To the extent it is is the former, revise to ensure you disclose
the correct number of
       shares outstanding. In this regard, we note from your Subsequent Events
footnote that an
       additional 474,702 were issued after March 31, 2021.
        You may contact Megan Akst, Senior Staff Accountant at 202-551-3407 or
Kathleen
Collins, Accounting Branch Chief at 202-551-3499 if you have questions
regarding comments
on the financial statements and related matters. Please contact Matthew Derby,
Staff Attorney at
202-551-3334 or Jan Woo, Legal Branch Chief at 202-551-3453 with any other
questions.



                                                             Sincerely,
FirstName LastNameFrank Magliochetti
                                                             Division of
Corporation Finance
Comapany NameClickStream Corporation
                                                             Office of
Technology
July 30, 2021 Page 2
cc:       David Ficksman
FirstName LastName