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                              May 11, 2020

       Vicky Sharma
       President
       Starguide Group, Inc.
       275 Jatwada, Dasna Gate near Old Bus Stand
       Ghaziabad, Uttar Pradesh, India 201002

                                                        Re: Starguide Group,
Inc..
                                                            Registration
Statement on Form S-1
                                                            Filed April 15,
2020
                                                            File No. 333-237681

       Dear Mr. Sharma:

              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.

       Form S-1 filed April 15, 2020

       General Information About our Company, page 5

   1.                                                   You state here that you
have been engaged in negotiation of supply and distribution
                                                        contracts. If so,
please revise your disclosure about your Business to explain the terms of
                                                        these contracts and the
identity of such supplier(s), consistent with Item 101(h)(4)(v) of
                                                        Regulation S-K.
       Description of Our Business, page 13

   2.                                                   It appears that you may
be a shell company as defined in Securities Act Rule 405, because
                                                        you have no or nominal
assets (or assets consisting solely of cash or cash equivalents),
                                                        and you have no or
nominal operations. Accordingly, please revise your prospectus,
                                                        including the cover
page and prospectus summary, to disclose that you are a shell
 Vicky Sharma
Starguide Group, Inc.
May 11, 2020
Page 2
         company; please further disclose in appropriate places, including the
Risk Factors section,
         the consequences, challenges and risks of that status and the
potential reduced liquidity or
         illiquidity of your securities. If you do not believe you are a shell
company, please
         provide us with your legal analysis in support of your belief.
3.       We note that you are planning to export Indian traditional art and
crafts. Please expand
         your business description to include the regulation of the export of
Indian art and crafts
         products. For example, please disclose, if applicable, whether you
will have to
         obtain an Import Export Code and an export license. You should also
discuss, if
         applicable, whether you have to register with the Indian Chamber of
Commerce in order
         to identify your products as Indian. These are only examples, your
discussion should
         cover the cost and how long it will take to obtain all approvals and
licenses that are
         applicable to your business. Please see Item 101(h)(4)(viii) and Item
101(h)(4)(ix) of
         Regulation S-K.
Election under Section 107(b) of the JOBS Act, page 16

4.       According to your disclosure here, you have elected to avail yourself
of the extended
         transition period for complying with new or revised accounting
standards under Section
         102(b)(1), please provide a risk factor explaining that this election
allows you to delay the
         adoption of new or revised accounting standards that have different
effective dates for
         public and private companies until those standards apply to private
companies. Also, state
         that as a result of this election, your financial statements may not
be comparable to
         companies that comply with public company effective dates. In
addition, please revise
         your registration statement cover page to clearly mark the box
indication that you have
         elected the transition period for complying with any new or revised
financial accounting
         standards provided by Section 7(a)(2)(B) of the Securities Act.
Exhibits
FirstName LastNameVicky Sharma
5.     Please file all required exhibits, such as the legal opinion in a timely
manner so that we
Comapany NameStarguide Group, Inc.
       may have time to review them before you request that your registration
statement become
       effective.
May 11, 2020 Page 2
FirstName LastName
 Vicky Sharma
FirstNameGroup, Inc.
Starguide LastNameVicky Sharma
Comapany NameStarguide Group, Inc.
May 11, 2020
May 11, 2020 Page 3
Page 3
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 Theresa Brillant, Staff Accountant at 202-551-3307 or
Bill Thompson,
Accounting Branch Chef at 202-551-3344 if you have questions regarding comments
on the
financial statements and related matters. Please contact Scott Anderegg, Staff
Attorney at 202-
551-3342 or Mara Ransom, Office Chief at 202-551-3264 with any other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Trade &
Services