TRONTron Inc.

We note that the certifications filed as Exhibits 32.1 and 32.2 refer to the annual report on Form 10-K for the year ended December 31, 2022, instead of the year ended December 31, 2023. Additionally, the names of the officers listed in the first sentence of the certification do not match the signatures of the CEO and CFO. Please file an amended Form 10-K with revised certifications that make these corrections.

Rest of the question

Item 9A. Controls and Procedures, page 25 We note your disclosure in the last sentence of the first paragraph on page 25 that the Company’s certifying officers have concluded that the Company’s disclosure controls and procedures are effective in reaching that level of assurance. However, we note that in the second paragraph you disclose that your Chief Executive Officer and principal financial officer concluded that your disclosure controls and procedures were ineffective to "ensure that the material information required to be included in our 2. Securities and Exchange Commission reports is accumulated and communicated to our management, including our principal executive and financial officer, recorded, processed, summarized and reported within the time periods specified in Securities and Exchange Commission rules and forms relating to the Company, based on the assessment and control of disclosure decisions currently performed by a small team." Please revise the apparent discrepancy between the conclusions in these two paragraphs. Also, we note your disclosure that management believes that the Company maintained effective internal control over financial reporting as of December 31, 2023. In light of the disclosure in the preceding paragraph that management concluded your disclosure controls and procedures were not effective, please explain to us how you were able to conclude that ICFR was effective for the same period. Item 4. Controls and Procedures , page 11 3. We note from your disclosure in this Form 10Q and the Form 10Qs for each of your quarters during fiscal 2024, that the Company’s certifying officers have concluded that the Company’s disclosure controls and procedures are effective in reaching that level of assurance. We also note the disclosure that there have not been any changes in internal controls over financial reporting. In light of the disclosure in the Form 10- K for the year ended December 31, 2023 that disclosure controls and procedures were not effective, please tell us how you were able to conclude for each of the 2024 quarters that disclosure controls and procedures are effective. Please advise or revise accordingly. As part of your response please provide the nature of any remediation efforts that have been completed.

The Company respectfully acknowledges the Staff’s comment and notes that the Company, on December 18, 2024 filed the entire annual report for the year ended December 31, 2023 as an amendment (the “Amendment”) along with revised certifications correcting the name of the Company’s Chief Executive Officer to Richard Miller and the reference to the annual report on Form 10-K for the fiscal year end to December 31, 2023. Read in the reply ↗