October 31, 2024

Isabel Marin Vargas
Director
Mercalot Inc.
C/ de l   Illa Formentera, 54, Quatre Carreres
46026 Valencia, Spain

        Re: Mercalot Inc.
            Amendment No. 1 to Registration Statement on Form S-1
            Filed October 10, 2024
            File No. 333-281804
Dear Isabel Marin Vargas:

     We have reviewed your amended registration statement and have the
following
comment(s).

        Please respond to this letter by amending your registration statement
and providing
the requested information. 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 any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our September
23,
2024 letter.

Amendment No. 1 to Registration Statement on Form S-1
Dilution, page 17

1.     We note your response to comment 8 and the related revisions to your
disclosure.
       Please further revise your calculation of net tangible book value to
exclude total
       liabilities.
General

2.     We note your response to comment 12 that you are "evaluating the market
value of
       your publicly held shares and aim to meet the required minimum of $15
million upon
       completion of the offering," and that you "plan to achieve the required
minimum $4
       per share bid price;" however, we note that you are registering up to
12,000,000
 October 31, 2024
Page 2

      shares of common stock at a fixed price of $0.01 per share for aggregate
net proceeds
      of up to $120,000, assuming that the entire offering is completed. Please
further
      explain how you plan to meet the listing requirements given the current
terms of the
      offering, or remove references to listing your common stock on the Nasdaq
Stock
      Market from the registration statement.
       Please contact Ta Tanisha Meadows at 202-551-3322 or Suying Li at
202-551-3335 if
you have questions regarding comments on the financial statements and related
matters. Please contact Rucha Pandit at 202-551-6022 or Taylor Beech at
202-551-4515 with
any other questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Trade &
Services