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                            April 18, 2024

       Tjin Patrick Soetanto
       Chief Executive Officer
       NusaTrip Incorporated
       28F AIA Central, Jl. Jend. Sudirman No.Kav. 48A
       RT.5/RW.4, Karet, Semanggi
       Kota Jakarta Selatan
       Daerah Khusus Ibukota
       Jakarta 12930, Indonesia

                                                        Re: NusaTrip
Incorporated
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Submitted March 29,
2024
                                                            CIK No. 0002006468

       Dear Tjin Patrick Soetanto:

            We have reviewed your amended draft registration statement and have
the following
       comments.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

               After reviewing the information you provide in response to this
letter and your amended
       draft registration statement or filed registration statement, we may
have additional
       comments. Unless we note otherwise, any references to prior comments are
to comments in our
       January 26, 2024 letter.

       Amendment No. 1 to Draft Registration Statement on Form S-1

       Cover Page

   1.                                                   In response to prior
comment 1, you provide an address in the U.S. but fail to name your
                                                        agent. Please name your
agent for service with a United States address.
   2.                                                   Disclose that your
Super Voting Preferred Stock is not convertible into common stock and
                                                        has no sunset
provision, if true.
 Tjin Patrick Soetanto
FirstName   LastNameTjin Patrick Soetanto
NusaTrip Incorporated
Comapany
April       NameNusaTrip Incorporated
       18, 2024
April 218, 2024 Page 2
Page
FirstName LastName
Prospectus Summary
Corporate Information, page 7

3.       Please tell us whether the terms and issuance of the Super Voting
Preferred Stock to
         Raynauld Liang and Maroon Capital Limited will impact the conclusion
that all operating
         entities of the registrant are under common control by SOPA. In this
regard we note you
         indicate on the cover page that "...Upon the consummation of this
offering, Raynauld
         Liang...and Maroon Capital Limited... will each control 25,000 Shares
of the Company   s
         Super Voting Preferred Stock, giving them a majority of the aggregate
voting power of the
         Company   s voting securities upon the consummation of this offering."
We reissue prior
         comment 11 in part.
Our historical financial information may not be representative of the results
we would have
achieved..., page 27

4.       We note your response to prior comment 31, which explains why an
allocation of shared
         costs incurred by Society Pass is not required. However, your response
is in conflict with
         the following statement in your risk factor disclosure on page 27:
"The costs and
         expenses reflected in our historical financial information include an
allocation for certain
         corporate functions historically provided by Society Pass, that may be
different from the
         comparable expenses that we would have incurred had we operated as a
stand-alone
         company." Please reconcile these statements and revise your
disclosure, as necessary.
Corporate History and Structure, page 37

5.       In response to comment 6 you revised to disclose that the Board of
Directors of Society
         Pass will approve a plan to separate your company from Society Pass,
to be achieved by
         "the authorization and issuance of up to [*] shares of our Common
Stock in connection
         with this offering." As part of this separation, please disclose the
separation and
         reorganization transactions that you will enter into with Society Pass
in order to transfer
         the assets and liabilities of its online travel agency business to
you, and disclose all
         related party agreements that detail the contractual obligations and
responsibilities of you
         and Society Pass that you intend to enter into prior to or
contemporaneously with the
         completion of this offering.
Consolidated Results of Operations, page 39

6.       We note revenues from hotel technology platform software service
decreased in fiscal
         year 2023 as compared to fiscal year 2022. However, the cost of
revenues associated with
         these services increased in fiscal year 2023. Please expand your
disclosures to explain the
         reasons for the inconsistent movement in balances between fiscal
periods.
7.       We note you included sales and withholding tax in your general and
administrative
         expenses. Please clarify revenue type related to this sales tax, the
nature of the
         withholding tax and the basis of including these taxes in general and
 Tjin Patrick Soetanto
FirstName   LastNameTjin Patrick Soetanto
NusaTrip Incorporated
Comapany
April       NameNusaTrip Incorporated
       18, 2024
April 318, 2024 Page 3
Page
FirstName LastName
         administrative expenses. Explain the reason for recording a provision
and why it was
         reversed during fiscal year 2023.
Prospectus Summary
Corporate Information, page 72

8.       We refer you to prior comment 20. Ensure that your disclosure is
consistent and tailored
         to your company and its operations. For example, you continue to show
multiple
         "impending acquisitions" at page 73, despite stating at page 1: "As of
the date of this
         prospectus, we have no current mergers or acquisitions pending or
contemplated."
Certain Relationships and Related-Party Transactions
Advances From/ To Related Parties, page 83

9.       We note your disclosure provided in response to comment 25 in terms of
the amount due
         to/from related parties at your most recent fiscal year ends. Please
revise to also disclose
         the amounts due to/from related parties as of the latest practicable
date. See Item
         404(a)(5) of Regulation S-K.
Report of the Independent Registered Public Accounting Firm, page F-2

10.      We note the audit report issued by Onestop Assurance PAC for your
fiscal year ended
         December 31, 2023 is dated March 26, 2023. Please ask your auditor to
resubmit the audit
         report with a corrected date.
Financial Statements
Note 3 Summary of Significant Accounting Policies, page F-8

11.      Please provide segment information in your footnotes as required by
ASC 280-10-50 or
         tell us why you believe that you are not subject to this accounting
standard.
12.      We note that you recognized online advertising revenue on a gross
basis. Please tell us
         how you record expenses related to this type of revenue and why no
costs of revenues
         have been incurred to date.
Revenue Recognition, page F-11

13.      We note your response to prior comment 34. Please clarify if you
record revenue for your
         ancillary services on a gross or net basis. We reissue prior comment
34 in part. Refer to
         ASC 606-10-55-36 through 55-40.
14.      We note your online advertising services are recognized on a gross
basis at a "point in
         time". However, you also indicate that advertising revenues are
"...recognized ratably over
         the fixed term of the agreement as services are provided or upon
relevant performance
         obligations being fulfilled through the display of the
advertisement..." Please clarify
         timing of your revenue recognition for your online advertising
services. We reissue prior
         comment 36 in part.
 Tjin Patrick Soetanto
FirstName   LastNameTjin Patrick Soetanto
NusaTrip Incorporated
Comapany
April       NameNusaTrip Incorporated
       18, 2024
April 418, 2024 Page 4
Page
FirstName LastName
Recently Issued Accounting Pronouncements, page F-17

15.      Please update these disclosures, as appropriate, to reflect the
adoption of new accounting
         pronouncements and the identification of newly issued accounting
pronouncements not
         yet adopted.
Note 4 Inventories, page F-18

16.      We note your response to comment 38. You state that revenues from air
tickets are
         recorded at a point in time when the traveler books the air
transaction and that you are not
         subject to inventory risk associated with these transactions.
Therefore, it remains unclear
         why air tickets are purchased in advance and held in inventory. Please
explain the process
         under which air ticketing results in amounts held in inventory, the
time period that tickets
         are held in inventory before recognized as revenue and how this
process supports your
         accounting for these transactions on a net basis.
Note 9 Shareholders' Equity, page F-20

17.      We note disclosures elsewhere in your filing regarding the designation
of Super Voting
         Preferred Stock on May 22, 2023. Please update your footnote
discussion here to reflect
         such designation with the nature and terms of preferred stock, as well
as your financial
         statements (including statements of changes in shareholders' equity)
and capitalization
         table.
Note 10 Income Taxes, page F-21

18.      Please clarify why you have not provided a full valuation allowance
against your deferred
         tax assets of PTTSM even though management believes it is more likely
than not that
         these assets will not be realized in the future. We reissue prior
comment 40 in part.
General

19.      We reissue prior comment 42. Please list or define the countries of
the Southeast
         geographic region, for which you provide the acronym "SEA."
       Please contact Joanna Lam at 202-551-3476 or Shannon Buskirk at
202-551-3717 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Timothy S. Levenberg at 202-551-3707 or Kevin Dougherty at 202-551-3271
with any
other questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Energy
& Transportation
 Tjin Patrick Soetanto
NusaTrip Incorporated
FirstName
April 18, 2024 LastNameTjin Patrick Soetanto
Comapany
Page    5      NameNusaTrip Incorporated
April 18, 2024 Page 5
cc:       Ted Paraskevas, Esq., of Loeb & Loeb LLP
FirstName LastName