SUPERBOX : Attorney Letter 11-22-21

J.M. Walker & Associates

Attorneys At Law

7841 South Garfield Way

Centennial, CO 80122

303-850-7637 [e-mail]303-482-2731 facsimile

November 22, 2021

OTC Markets Group, Inc.

300 Vesey Street, 12th Floor

New York, N.Y. 10282

Re: Letter with Respect to Adequate Current Information for

Superbox, Inc.

Dear Sir or Madam:

The undersigned is writing this letter in connection with the information publicly disclosed by the Issuer and published in the OTC Disclosure and News Service. OTC Markets Group, Inc. ("OTC Markets Group") is entitled to rely on this letter in determining whether the Issuer has made adequate current information publicly available within the meaning of Rule 144(c)(2) under the Securities Act of 1933 (the "Securities Act").

The undersigned is a U.S. resident and has been retained by the Issuer for the purposes of rendering this letter and related matters. The undersigned serves as the Issuer's outside securities counsel. The undersigned does not beneficially own any shares of the Issuer's securities. The undersigned has not received, nor has an agreement to receive in the future, shares of the issuer's stock, in payment for services. The undersigned is authorized to practice law in the State of Colorado. The jurisdictions covered by this letter are limited to the laws of the State of Colorado and the laws of the United States and the undersigned does not express any opinion concerning any other law. The undersigned is permitted to practice before the Securities and Exchange Commission ("SEC") and has not been prohibited from practice thereunder.

The undersigned has examined such corporate records and other documents and such questions of law as the undersigned considered necessary or appropriate for purposes of rendering this letter. The undersigned has assumed that (i) all information contained in all documents reviewed by the undersigned is true and correct; (ii) all signatures on all documents reviewed by the undersigned are genuine; (iii) all documents submitted to the undersigned as originals are true and complete; (iv) all documents submitted to the undersigned as copies are true and complete copies of the originals thereof; and (v) each natural person signing any document reviewed by the undersigned had the legal capacity to do so. As to matters of fact, the undersigned has relied on information obtained from public officials, officers of the Issuer, and other sources that the undersigned believed to be reliable sources.

The undersigned is not currently nor has been in the past five years, been the subject of an investigation, hearing, or proceeding by the SEC, the U.S. Commodity Futures Trading Commission (CFTC), the Financial Industry Regulatory Authority (FINRA), or any other federal, state, or foreign regulatory agency.

The undersigned is not currently, nor has been in the past five years, suspended or barred from practicing in any state or jurisdiction. Counsel has not been charged in a civil or criminal case.

The documents containing the information concerning the Issuer and the securities that is publicly available and the undersigned has reviewed in connection with the preparation of this letter (the "Information") and the dates that such documents were posted in the OTC Disclosure and News Service are the following:

Annual Report - Superbox Financials - Period End Date January 1, 2020 posted November 15, 2021

Annual Report - Superbox OTC Pink Basic Disclosure Statement - Period End Date January 1, 2020 posted November 22, 2021

Annual Report - Superbox Financials - Period End Date January 1, 2021 posted November 15, 2021

Annual Report - Superbox OTC Pink Basic Disclosure Statement - Period End Date January 1, 2021 posted November 22, 2021

Quarterly Report - Superbox Financials - Period End Date April 30, 2021 posted November 22, 2021

Quarterly Report - Superbox OTC Pink Basic Disclosure Statement - Period End Date April 30, 2021 post November 22, 2021

Quarterly Report - Superbox Financials - Period End Date July 31, 2021 posted November 22, 2021

Quarterly Report - Superbox OTC Pink Basic Disclosure Statement - Period End Date July 31, 2021 post November 22, 2021

Quarterly Report - Superbox Financials - Period End Date October 31, 2021 posted November 22, 2021

Quarterly Report - Superbox OTC Pink Basic Disclosure Statement - Period End Date October 31, 2021 post November 22, 2021

The undersigned has (i) personally met with Andrea Piazzoli, Giovanni Alfano and Claudio Mirella, officers and directors of the Issuer; (ii) reviewed the Information, as amended, published by the Issuer on the OTC Disclosure News Service; and (iii) discussed the Information with the sole officer and director of the Issuer.

It is the opinion of the undersigned that the Information (i) constitutes "adequate current public information" concerning the securities and the Issuer and "is available" within the meaning of Rule 144(c)(2) under the Securities Act; (ii) includes all of the information that a broker-dealer would be required to obtain from the Issuer to publish a quotation for the securities under the Securities Exchange Act of 1934 (the "Exchange Act"); (iii) complies as to form with the OTC Markets Group Pink Basic Disclosure Guidelines, which are located on the Internet at www.otcmarkets.com; (iv) has been posted in the OTC Disclosure & News Service.

The person responsible for the preparation of the financial statements contained in the Annual Reports is David Natan. Mr. Natan has over 40 years of accounting experience having served as CFO of five listed public companies. The annual financial statements as of January1, 2021 and 2020 are without audit.

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The Issuer's transfer agent is Pacific Stock Transfer Company. Pacific Stock Transfer Company is registered as a transfer agent with the SEC. To confirm the number of outstanding shares set forth in the Information, the undersigned relied on information provided to the undersigned by Pacific Stock Transfer Company, including stock ledgers, position reports, and verbal communications. In addition, the undersigned relied on information provided by the Issuer, including subscription and other agreements and corporation resolutions.

To the best of the undersigned's knowledge, after inquiry of management and the directors of the Issuer, neither the Issuer, any 5% holder, nor the undersigned is currently under investigation by any federal or state regulatory authority for any violation of federal or state securities laws.

This letter is rendered solely for use by OTC Markets Group. OTC Markets Group has full and complete permission and rights to publish the letter through the OTC Disclosure & News Service for public viewing. This letter may not be relied upon by any party other than OTC Markets Group for any reason whatsoever.

We have considered the question as to whether the Issuer, including its predecessors, is or ever was a "shell company" as defined in Rules 405 of the Securities Act of 1933 of the Securities Act of 1933 and 12b-2 of the Exchange Act of 1934 and has concluded that it is not now a "shell company." However, given the length of time in which the Issuer has been in existence, we are unable to conclude that it has never been a "shell company."

Very truly yours,

J.M. Walker & Associates

______________________________________

Jody M. Walker, Attorney At Law