SEC Comment Letter 0000000000-24-004180 to Invech Holdings, Inc. (IVHI)
Invech Holdings, Inc.
Date: April 17, 2024 · CIK: 0001009919 · Accession: 0000000000-24-004180
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-276779
Letter
United States securities and exchange commission logo April 17, 2024 Rhonda Keaveney Chief Executive Officer Invech Holdings, Inc. 7339 E. Williams Drive Unit 26496 Scottsdale, AZ 85255 Re:Invech Holdings, Inc. Amendment No. 3 to Registration Statement on Form S-1 Filed April 9, 2024 File No. 333-276779 Dear Rhonda Keaveney: 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 April 2, 2024 letter. Amendment No. 3 to Registration Statement on Form S-1 Filed April 9, 2024 Item 16. Exhibits and Financial Statement Schedules, page F-1 1.We note your response to our prior comment 2 and related revisions and reissue our comment with a clarification. Please revise to eliminate the label "unaudited" throughout pages F-3 through F-9 as they represent audited financial statements and related notes. See the bottom of pages F-3 through F-6 and Notes 2, 3, and 6 on pages F-7 through F-9. General 2.We note your response to prior comment 4 and reissue our comment in entirety. Please have your auditor provide an updated consent to reflect the appropriate report date and periods presented in the financial statements included in the filing.
FirstName LastNameRhonda Keaveney Comapany NameInvech Holdings, Inc. April 17, 2024 Page 2 FirstName LastName Rhonda Keaveney Invech Holdings, Inc. April 17, 2024 Page 2 Please contact Stephen Kim at 202-551-3291 or Joel Parker at 202-551-3651 if you have questions regarding comments on the financial statements and related matters. Please contact Jenna Hough at 202-551-3063 or Donald Field at 202-551-3680 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
April 17, 2024
Rhonda Keaveney
Chief Executive Officer
Invech Holdings, Inc.
7339 E. Williams Drive
Unit 26496
Scottsdale, AZ 85255
Re:Invech Holdings, Inc.
Amendment No. 3 to Registration Statement on Form S-1
Filed April 9, 2024
File No. 333-276779
Dear Rhonda Keaveney:
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 April 2, 2024 letter.
Amendment No. 3 to Registration Statement on Form S-1 Filed April 9, 2024
Item 16. Exhibits and Financial Statement Schedules, page F-1
1.We note your response to our prior comment 2 and related revisions and reissue our
comment with a clarification. Please revise to eliminate the label "unaudited" throughout
pages F-3 through F-9 as they represent audited financial statements and related notes. See
the bottom of pages F-3 through F-6 and Notes 2, 3, and 6 on pages F-7 through F-9.
General
2.We note your response to prior comment 4 and reissue our comment in entirety. Please
have your auditor provide an updated consent to reflect the appropriate report date and
periods presented in the financial statements included in the filing.
FirstName LastNameRhonda Keaveney
Comapany NameInvech Holdings, Inc.
April 17, 2024 Page 2
FirstName LastName
Rhonda Keaveney
Invech Holdings, Inc.
April 17, 2024
Page 2
Please contact Stephen Kim at 202-551-3291 or Joel Parker at 202-551-3651 if you have
questions regarding comments on the financial statements and related matters. Please contact
Jenna Hough at 202-551-3063 or Donald Field at 202-551-3680 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services