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August 2, 2022
Farid Shouekani
Chief Executive Officer
Viper Networks, Inc.
200 E Big Beaver Rd.
Troy, MI 48083
Re:Viper Networks, Inc.
Offering Statement on Form 1-A
Filed July 22, 2022
File No. 024-11948
Dear Mr. Shouekani:
            We have reviewed your offering statement and have the following comments.  In some of
our comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to this letter by amending your offering statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.  After reviewing any amendment to your offering statement and the information you
provide in response to these comments, we may have additional comments.
Offering Statement on Form 1-A
General
1.We note that your signature on behalf of the issuer appears to relate to a different
company.  Please revise to ensure your signature page complies with the requirements of
Form 1-A.  See Instruction 1 to Signatures to Form 1-A.
2.We note that you intend to offer 10,000,000,000 shares of common stock, but that your
balance sheet indicates you are authorized to issue 6,000,000,000 shares of common
stock.  We also note the Articles of Amendment to the Articles of Incorporation dated
April 30, 1998, included as Exhibit 2.1, authorize the issuance of 50,000,000 shares of
common stock.  Please amend your disclosure to address this discrepancy.  If applicable,
please file your current Articles of Incorporation as an exhibit to the offering statement.

 FirstName LastNameFarid Shouekani
 Comapany NameViper Networks, Inc.
 August 2, 2022 Page 2
 FirstName LastName
Farid Shouekani
Viper Networks, Inc.
August 2, 2022
Page 2
            We will consider qualifying your offering statement at your request.  In connection with
your request, please confirm in writing that at least one state has advised you that it is prepared
to qualify or register your offering.  If a participant in your offering is required to clear its
compensation arrangements with FINRA, please have FINRA advise us that it has no objections
to the compensation arrangements prior to qualification.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Please contact Alyssa Wall at 202-551-8106 or Jennifer López Molina at 202-551-3792
with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Jeff Turner