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United States securities and exchange commission logo





                            June 6, 2023

       Mark Douglas
       Chief Executive Officer
       MNTN, Inc.
       823 Congress Avenue
       #1827
       Austin, TX 78768

                                                        Re: MNTN, Inc.
                                                            Amendment No. 5 to
Draft Registration Statement on Form S-1
                                                            Submitted May 12,
2023
                                                            CIK No. 0001891027

       Dear Mark Douglas:

             We have reviewed your amended draft 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 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 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Amendment No. 5 to Draft Registration Statement on Form S-1 Submitted
May 12, 2023

       Prospectus Summary
       Competitive Strengths
       Business Model Allows for High Growth and Profitability, page 5

   1.                                                   Please revise the
profitability aspect of the heading for this paragraph, as well as the
                                                        related disclosure, to
take into account that in recent fiscal years your performance has
                                                        trended away from,
rather than toward, achieving profitability. In this regard, we note
                                                        your net income/loss
results for the fiscal years ended December 31, 2020, 2021 and 2022.
                                                        Please make conforming
revisions in the business section.
 Mark Douglas
MNTN, Inc.
June 6, 2023
Page 2
Capitalization, page 57

2.       Please explain why you did not include the short-term note payable
balance of $38,956 as
         of December 31, 2022, as part of your indebtedness or revise
accordingly.
       You may contact Scott Stringer at 202-551-3272 or Lyn Shenk at
202-551-3380 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Nicholas Nalbantian at 202-551-7470 or Dietrich King at 202-551-8071
with any other
questions.



FirstName LastNameMark Douglas                               Sincerely,
Comapany NameMNTN, Inc.
                                                             Division of
Corporation Finance
June 6, 2023 Page 2                                          Office of Trade &
Services
FirstName LastName
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