Correspondence 0001683168-24-002581 from Invech Holdings, Inc. (IVHI)
Invech Holdings, Inc.
Date: April 22, 2024 · CIK: 0001009919 · Accession: 0001683168-24-002581
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File numbers found in text: 333-276779
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CORRESP
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INVECH HOLDINGS, INC.
7339 E. Williams Drive
Unit 26496
Scottsdale, AZ 85255
April 22, 2024
Ms. Jenna Hough
Division of Corporation Finance
Office of Trade & Services
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re:
Invech Holdings, Inc.
Amendment No. 4 of the Registration Statement on Form S-1
Filed April 17, 2024
File No. 333-276779
Dear Ms. Hough:
Set forth below are the responses of Invech Holdings,
Inc., a Nevada corporation (“IVHI” “we,” “us,”
“our” or the “Company”), to the comments received from you, the Division of Corporation
Finance of the U.S. Securities and Exchange Commission (the “SEC”) by emailed letter, dated April 19, 2024,
with respect to (i) our Amendment No. 4 of the Registration Statement on Form S-1 filed on April 17, 2024. The responses
provided below are numbered to correspond to your comments, which have been reproduced and emboldened herein for ease of reference.
Amendment No.4 to Registration Statement on Form S-1Filed
April 17, 2024
General
1. We note your response
to prior comment 2 and a related revision and reissue our comment in its entirety with a clarification. Please have your auditor provide
an updated consent (originally included with Form S-1 filed January 30, 2024 as Exhibit 23.1) to reflect the appropriate audit report
date (i.e. April 17, 2024 as disclosed on page F-2) and periods presented in the financial statements included in the filing (i.e. for
the years ended December 31, 2023 and 2022).
Response:
The updated auditor consent has replaced the stale consent as Exhibit
23.1.
If you have any questions or comments concerning this response, please
call Rhonda Keaveney, our CEO, at (602) 793 -8058 or email Ms. Keaveney at rhonda@scctransferllc.com.
Sincerely,
Invech Holdings, Inc.
By:
/s/ Rhonda Keaveney
Rhonda Keaveney
Chief Executive Officer