Form RW Pro Music Rights, Inc

PRO MUSIC RIGHTS, INC.

3811 AIRPORT PULLING RD N STE 203

NAPLES, FL 34102

May 25, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Request to Withdraw Registration Statement on Form S-1

File No. 333-251807

Ladies and Gentlemen:

Pro Music Rights, Inc. (the “Company”) hereby respectfully requests that the Securities and Exchange Commission (the “Commission”) consent to the withdrawal, effective as of the date hereof or at the earliest practicable date hereafter, of the Company’s Registration Statement on Form S-1 (File No. 333-251807) together with all exhibits and amendments thereto (collectively, the “Registration Statement”), pursuant to Rule 477 under the Securities Act of 1933, as amended (the “Securities Act”). The Registration Statement was originally filed with the Commission on December 30, 2020.

The Registration Statement has not been declared effective by the Commission and no securities have been issued or sold pursuant to the Registration Statement. The Company is withdrawing the Registration Statement because it has determined not to pursue an initial public offering of its securities. The Company further requests that, in accordance with Rule 457(p) under the Securities Act, all fees paid to the Commission in connection with the filing of the Registration Statement be credited to the Company’s account.

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