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November 15, 2022
Vikram Grover
Chief Executive Officer
Himalaya Technologies, Inc.
1 E. Erie St., Ste. 525, Unit #2420
Chicago, IL 60611
Re:Himalaya Technologies, Inc.
Amendment No. 4 to Offering Statement on Form 1-A
Filed November 2, 2022
File No. 024-11980
Dear Vikram Grover:
            We have reviewed your amended 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.
Amendment No. 4 to Offering Statement on Form 1-A filed November 2, 2022
Our Business, page 8
1.We note your disclosure that on October 28, 2022 you signed a purchase agreement to
acquire the assets of a company that provides training software for the agriculture sector.
Please provide us with your analysis related to the significance of this acquisition
and whether you are required to include audited financial statements and pro forma
information. Refer to Part F/S of Form 1-A and Rules 8-04 and 8-05 of Regulation S-X.

 FirstName LastNameVikram Grover
 Comapany NameHimalaya Technologies, Inc.
 November 15, 2022 Page 2
 FirstName LastName
Vikram Grover
Himalaya Technologies, Inc.
November 15, 2022
Page 2
            You may contact Cheryl Brown, Staff Attorney, at (202) 551-3905 or Loan Lauren
Nguyen, Legal Branch Chief, at (202) 551-3642 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       Milan Saha, Esq.