Correspondence 0001683168-24-006630 from Invech Holdings, Inc. (IVHI)
Invech Holdings, Inc.
Date: Sept. 24, 2024 · CIK: 0001009919 · Accession: 0001683168-24-006630
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. 10 of the Registration Statement on Form S-1 Filed August 29, 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 September 11, 2024, with respect to (i) our Amendment No. 10 of the Registration Statement on Form S-1 filed on August 29, 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. 10 to Registration Statement on Form S-1 Filed August 29, 2024
General
1. We note your response to prior comment 1 and reissue our comment in full. 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:
Financials have been updated.
2. We note that your auditor provided a consent to the use of its audit report that was dated July 10, 2024. Given the extended period of time that has passed since this consent was provided, please file an updated consent from your auditor.
Response:
Updated consent letter has been filed 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.
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CORRESP
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INVECH HOLDINGS, INC.
7339 E. Williams Drive
Unit 26496
Scottsdale, AZ 85255
September 24, 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. 10 of the Registration Statement on Form S-1
Filed August 29, 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 September 11,
2024, with respect to (i) our Amendment No. 10 of the Registration Statement on Form S-1 filed on August 29, 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. 10 to Registration Statement on Form S-1 Filed
August 29, 2024
General
1. We note your response
to prior comment 1 and reissue our comment in full. 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:
Financials have been updated.
2. We note that your auditor
provided a consent to the use of its audit report that was dated July 10, 2024. Given the extended period of time that has passed since
this consent was provided, please file an updated consent from your auditor.
Response:
Updated consent letter has been filed 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