Correspondence 0001683168-24-005787 from Invech Holdings, Inc. (IVHI)
Invech Holdings, Inc.
Date: Aug. 15, 2024 · CIK: 0001009919 · Accession: 0001683168-24-005787
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-276779
Letter
Division of Corporation Finance Office of Trade & Services Securities and Exchange Commission Re: Invech Holdings, Inc. Amendment No. 8 of the Registration Statement on Form S-1 Filed August 6, 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 August 14, 2024, with respect to (i) our Amendment No. 8 of the Registration Statement on Form S-1 filed on August 6, 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. 8 to Form S-1 filed August 6, 2024
Certain Relationships and Related Transactions, and Director Independence, page 50
1. We note your revised disclosure pursuant to comment 2 and reissue in part. Please disclose each transaction disclosed in Note 7 of the interim financial statements, specifically the additional $16,159 advance from SCC.
Response:
The following language was inserted:
Subsequent to March 31, 2024, SCC advanced the Company $16,159 to pay for transfer agent fees, accounting fees, and general operating expenses. The advance is non-interest bearing and due on demand.
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.
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INVECH HOLDINGS, INC.
7339 E. Williams Drive
Unit 26496
Scottsdale, AZ 85255
August 15, 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. 8 of the Registration Statement on Form S-1
Filed August 6, 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 August 14,
2024, with respect to (i) our Amendment No. 8 of the Registration Statement on Form S-1 filed on August 6, 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. 8 to Form S-1 filed August 6, 2024
Certain Relationships and Related Transactions, and Director
Independence, page 50
1. We note your revised disclosure
pursuant to comment 2 and reissue in part. Please disclose each transaction disclosed in Note 7 of the interim financial statements, specifically
the additional $16,159 advance from SCC.
Response:
The following language was inserted:
Subsequent to March 31, 2024, SCC advanced the Company $16,159 to pay
for transfer agent fees, accounting fees, and general operating expenses. The advance is non-interest bearing and due on demand.
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