April 8, 2020

Mario Todd
Chief Executive Officer
Stark Focus Group, Inc.
Suite 3001, 505 6th Street SW
Calgary AB T2P 1X5

       Re: Stark Focus Group, Inc.
           Registration Statement on Form S-1
           Filed March 12, 2020
           File No. 333-237100

Dear Mr. Todd:

       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

Cover Page

1.     Please disclose that your officers and directors hold the majority
voting power and will
       continue to do so after this offering. In this regard, we note that they
own, as a group,
       82.2% of your issued and outstanding shares of common stock and will
continue to own
       approximately 80% of the common stock after this offering.

Year Ended December 31, 2019 compared to December 31, 2018, page 28

2.     Please revise to discuss the source of your revenues of $26,064 for the
period ended
       December 31, 2019. In addition, to the extent that you have material
agreements related
 Mario Todd
Stark Focus Group, Inc.
April 8, 2020
Page 2
         to this revenue, please discuss their terms in your Description of
Business section and file
         the agreements as exhibits with your next amendment. Refer to Item 601
of Regulation S-
         K.
Business, page 30

3.       It is unclear to what extent you have commenced operations. Please
expand upon your
         current operations and revenue generating activities. In this regard,
we note your
         disclosure that "[t]he Company, through Common Design, currently
sources products
         from other supplier and distributes such products to its customers,"
however, your
         Business section only describes future marketing, pricing and sales
tactics. If you have not
         commenced operations, please revise your disclosure to provide a more
detailed
         discussion of each of your planned activities for the next 12 months.
For example, discuss
         the milestones necessary to design, launch and develop each aspect of
your proposed
         business, and the total costs and timing related to each step.
4.       Please revise to add a separately captioned section or sections to
address in detail the
         applicability of Chinese and other foreign regulations to you and your
business. Clarify
         the status of your compliance and set forth the remaining steps or
hurdles required to
         comply or maintain compliance with the applicable rules.
5.       In light of your risk factor disclosure on page 14, please address the
challenges you may
         experience in your business operations or implementation of your
business plan as a result
         of the coronavirus pandemic and its potential effect on your financial
condition, if any.
         For example, discuss changes to your supply chain that have been, or
may in the future be,
         necessitated by the coronavirus pandemic. Refer to Corporation
         Finance Disclosure Topic No. 9.
Established Network, page 34

6.       Given your very limited history of revenues, please expand your
disclosure to discuss the
         strength and dependability of your "solid, reliable network of
contacts" with
         manufacturers, distributors and major buyers.
Signature Page, page 47
FirstName LastNameMario Todd
7.     Please revise to identify your principal executive officer, principal
financial officer, and
Comapany NameStark Focus Group, Inc.
       principal accounting officer to conform to the requirements of the
Signatures section of
April 8, 2020S-1. See Instructions 1 and 2 to Signatures on Form S-1.
       Form Page 2
FirstName LastName
 Mario Todd
FirstName LastNameMario Todd
Stark Focus Group, Inc.
Comapany NameStark Focus Group, Inc.
April 8, 2020
April 3 2020 Page 3
Page 8,
FirstName LastName
        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 Stephen Kim at (202) 551-3291 or Robyn Manuel at (202)
551-3823 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Daniel Morris at (202) 551-3314 or Jennifer L pez at (202) 551-3792
with any other
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Trade &
Services
cc:      Jonathan Lotz