February 1, 2019

Olegas Tunevicius
Chief Executive Officer
BIGEON CORP.
Manesova 345/13 Ceske Budejovice 6
Ceske Budejovice, Czech Republic

       Re: BIGEON CORP.
           Registration Statement on Form S-1
           Filed December 14, 2018
           File No. 333-228803

Dear Mr. Tunevicius:

       We have reviewed your 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.

Registration Statement on Form S-1

Our Product, page 21

1.     Please disclose when product development began, the material hurdles
that remain, and an
       estimated timeline for completion of the application and subsequent
listing on digital
       distribution platforms.
Management, page 29

2.     Please clarify your disclosure regarding Mr. Tenevicius' business
experience at Egzotika
       and Latakko, including his position at Egzotika and relevant time
periods. Refer to
       Item 401(e) of Regulation S-K.
3.     Please provide the information required by Item 404(a) of Regulation
S-K. In this regard,
 Olegas Tunevicius
FirstNameCORP.
BIGEON LastNameOlegas Tunevicius
Comapany NameBIGEON CORP.
February 1, 2019
February 1, 2019 Page 2
Page 2
FirstName LastName
         exhibit 10.7 indicates that you provided an interest free loan to the
company in the amount
         of $65,000.
Security Ownership of Certain Beneficial Owners, page 31

4.       Please revise the beneficial ownership table to present Mr.
Tunevicius' post-offering
         ownership percentages assuming various levels of completion of the
offering.
Signatures, page 59

5.       Instruction 1 to Signatures of Form S-1 requires signatures of your
principal executive
         officer or officers, your principal financial officer, your controller
or principal accounting
         officer and at least a majority of the board of directors or persons
performing similar
         functions. As you are signing in more than one capacity, indicate each
capacity in which
         you are signing.
General

6.       You appear to be a shell company as defined in Rule 405 under the
Securities Act of 1933
         because you have no or nominal operations and assets consisting solely
of cash and cash
         equivalents. Please disclose on the cover page that you are a shell
company and add a risk
         factor that highlights the consequences of your shell company status.
Discuss the
         prohibition on the use of Form S-8 by shell companies, enhanced
reporting requirements
         imposed on shell companies, and the conditions that must be satisfied
before restricted
         and control securities may be resold in reliance on Rule 144. Also,
describe the potential
         impact on your ability to attract additional capital through
subsequent unregistered
         offerings.
7.       It appears your offices, assets, directors and management are located
outside of the United
         States. Please disclose the limitations on U.S. investors for bringing
claims outside of the
         U.S. Please also explain the limitations on their ability to effect
service of process on the
         officers and directors and enforce judgments obtained in the U.S.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Amanda Kim, Staff Accountant, at (202) 551-3241 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
Matthew Derby, Staff
Attorney, at (202) 551-3334 or Barbara Jacobs, Assistant Director, at (202)
551-3735 with any
 Olegas Tunevicius
BIGEON CORP.
February 1, 2019
Page 3

other questions.



                                      Sincerely,
FirstName LastNameOlegas Tunevicius
                                      Division of Corporation Finance
Comapany NameBIGEON CORP.
                                      Office of Information Technologies
February 1, 2019 Page 3               and Services
FirstName LastName