November 13, 2024

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

        Re: Mercalot Inc.
            Amendment No. 2 to Registration Statement on Form S-1
            Filed November 4, 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 October 31,
2024 letter.

Amendment No. 2 to Registration Statement on Form S-1
Dilution, page 17

1.     We note your response to prior comment 1 and your revised disclosure.
Please update
       your calculations using amounts as of September 30, 2024, the latest
balance sheet
       date presented.
 November 13, 2024
Page 2

       Please contact Ta Tanisha Meadows at 202-551-3322 or Suying Li at
202-551-3335
with any questions.



                                                       Sincerely,

                                                       Division of Corporation
Finance
                                                       Office of Trade &
Services