SEC Comment Letter 0000000000-24-009670 to Invech Holdings, Inc. (IVHI)
Invech Holdings, Inc.
Date: Aug. 23, 2024 · CIK: 0001009919 · Accession: 0000000000-24-009670
AI Filing Summary & Sentiment
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File numbers found in text: 333-276779
Letter
August 23, 2024 Rhonda Keaveney Chief Executive Officer Invech Holdings, Inc. 7339 E. Williams Drive Unit 26496 Scottsdale, AZ 85255 Re:Invech Holdings, Inc. Amendment No. 9 to Registration Statement on Form S-1 Filed August 16, 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 August 14, 2024 letter. Amendment No. 9 to Registration Statement on Form S-1 General 1.Please update your financial statements pursuant to Rule 3-12 of Regulation S-X to include the financial statements for the latest interim period in 2024. Update the associated financial information in applicable sections of the filing as appropriate. 2.We note that Exhibit 5.1 references the offering of 2,462,293 shares. We also note that you revised the offering to cover the offering of 3,277,416 shares by the selling shareholders. Please have legal counsel revise their legal opinion and refile it as Exhibit 5.1.
August 23, 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 cc:Rhonda Keaveney
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August 23, 2024
Rhonda Keaveney
Chief Executive Officer
Invech Holdings, Inc.
7339 E. Williams Drive
Unit 26496
Scottsdale, AZ 85255
Re:Invech Holdings, Inc.
Amendment No. 9 to Registration Statement on Form S-1
Filed August 16, 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 August 14, 2024 letter.
Amendment No. 9 to Registration Statement on Form S-1
General
1.Please update your financial statements pursuant to Rule 3-12 of Regulation S-X to
include the financial statements for the latest interim period in 2024. Update the
associated financial information in applicable sections of the filing as appropriate.
2.We note that Exhibit 5.1 references the offering of 2,462,293 shares. We also note that
you revised the offering to cover the offering of 3,277,416 shares by the selling
shareholders. Please have legal counsel revise their legal opinion and refile it as Exhibit
5.1.
August 23, 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
cc:Rhonda Keaveney