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Correspondence 0001683168-24-007410 from Invech Holdings, Inc. (IVHI)

Invech Holdings, Inc.
Date: Oct. 28, 2024 · CIK: 0001009919 · Accession: 0001683168-24-007410

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File numbers found in text: 333-276779

Date
October 28, 2024
Author
/s/ Rhonda Keaveney
Form
CORRESP
Company
Invech Holdings, Inc.

Letter

Via EDGAR Division of Corporation Finance Securities and Exchange Commission Attention: Jenna Hough, Esq. Re: Invech Holdings, Inc. Registration Statement on Form S-1 File No. 333-276779

Dear Ms. Hough:

In accordance with Rule 461 promulgated pursuant to the Securities Act of 1933, Invech Holdings, Inc. is hereby requesting that the effective date of the above-referenced Registration Statement on Form S-1 be accelerated so that it will become effective on 4:00 pm, Eastern October 30, 2024, or as soon as may be practicable.

If you have any questions regarding this request, please contact Rhonda Keaveney, our CEO at (602) 793-8058.

Sincerely,
/s/ Rhonda Keaveney

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CORRESP
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Invech Holdings, Inc.

PO Box 26496

Scottsdale, AZ 85255

October 28, 2024

Via EDGAR

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D. C. 20549

Attention: Jenna Hough, Esq.

    Re:
    Invech Holdings, Inc.

    Registration Statement on Form S-1

    File No. 333-276779

Dear Ms. Hough:

In accordance with Rule 461 promulgated pursuant
to the Securities Act of 1933, Invech Holdings, Inc. is hereby requesting that the effective date of the above-referenced Registration
Statement on Form S-1 be accelerated so that it will become effective on 4:00 pm, Eastern October 30, 2024, or as soon as
may be practicable.

If you have any questions
regarding this request, please contact Rhonda Keaveney, our CEO at (602) 793-8058.

    Sincerely,

    /s/ Rhonda Keaveney

    Rhonda Keaveney

    Chief Executive Officer