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             July 21, 2022

       Howard Marks
       Chief Executive Officer
       StartEngine Crowdfunding, Inc.
       3900 West Alameda Avenue
       Suite 1200
       Burbank, CA 91505

                                                        Re: StartEngine
Crowdfunding, Inc.
                                                            Amendment No. 1 to
Form 10-12G
                                                            Filed June 6, 2022
                                                            File No. 000-56415

       Dear Mr. Marks:

               We issued comments to you on the above captioned filing on June
22, 2022. As of the
       date of this letter, these comments remain outstanding and unresolved.
We expect you to
       provide a complete, substantive response to these comments by August 4,
2022.

               If you do not respond, we will, consistent with our obligations
under the federal securities
       laws, decide how we will seek to resolve material outstanding comments
and complete our
       review of your filing and your disclosure. Among other things, we may
decide to release
       publicly, through the agency's EDGAR system, all correspondence,
including this letter, relating
       to the review of your filings, consistent with the staff's decision to
publicly release comment and
       response letters relating to disclosure filings it has reviewed.

              Please contact Eric Envall at (202) 551-3234 or David Lin at
(202) 551-3552 with any
       questions.




             Sincerely,


             Division of Corporation Finance

             Office of Finance