Correspondence 0001683168-24-006102 from Invech Holdings, Inc. (IVHI)
Invech Holdings, Inc.
Date: Aug. 29, 2024 · CIK: 0001009919 · Accession: 0001683168-24-006102
AI Filing Summary & Sentiment
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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. 9 of the Registration Statement on Form S-1 Filed August 16, 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 23, 2024, with respect to (i) our Amendment No. 9 of the Registration Statement on Form S-1 filed on August 16, 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. 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.
Response:
We believe the financial statements have been filed pursuant to Rule 3-12 of Regulation S-X. On August 12, 2024 we filed Form 10-Q for period ending June 30, 2024
S-1, Amendment 8 was filed on August 6, 2024. At the time of this filing, the financials were current for the interim period as filed on this amendment. Shortly after the filing of Amendment 8, Q2 financials became due, and we filed the above mentioned 10-Q. At that time, we had not received additional SEC comment letters and could not have anticipated when, or if, another SEC comment letter would be received.
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.
Response:
Legal counsel has revised Exhibit 5.1 and the legal opinion was refiled.
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 29, 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. 9 of the Registration Statement on Form S-1
Filed August 16, 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 23,
2024, with respect to (i) our Amendment No. 9 of the Registration Statement on Form S-1 filed on August 16, 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. 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.
Response:
We believe the financial statements have been filed pursuant to Rule
3-12 of Regulation S-X. On August 12, 2024 we filed Form 10-Q for period ending June 30, 2024
S-1, Amendment 8 was filed on August 6, 2024. At the time of this filing,
the financials were current for the interim period as filed on this amendment. Shortly after the filing of Amendment 8, Q2 financials
became due, and we filed the above mentioned 10-Q. At that time, we had not received additional SEC comment letters and could not have
anticipated when, or if, another SEC comment letter would be received.
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.
Response:
Legal counsel has revised Exhibit 5.1 and the legal opinion was refiled.
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