SecProbe.io

Mail Stop 3720

September 20 , 2016

Robertson J. Orr
Chief Executive Officer
Bollente Companies, Inc.
8800 N. Gainey Dr., Suite 270
Scottsdale, AZ 85258

Re: Bollente Companies, Inc.
Form 10 -K for Fiscal  Year Ended December 31, 2015
Filed May 9, 2016
Form 10 -Q for Fiscal  Quarter Ended June 30, 2016
Filed August 22 , 2016
  File No. 000 -54219

Dear Mr. Orr :

We have reviewed your filing and have the following comments.  Please comply with
these comments in future filings.  Confirm in writing that you will do so.  In some of our
comments, we may ask you to provide us with information so we may better understand  your
disclosure.

Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please te ll us why in your response.

After reviewing your response to these comments, we may have additional comments.

Form 10 -K for Fiscal Year Ended December 31, 2015

Business, page 4

1. You disclose that you manufacture and distribute trutankless electric wat er heaters,  online
control panels, water circulation pump s and your new line of electric tankless  water
heaters geared toward budget -driven customers.  It is not clear from your disclosure the
extent to which each of these products is commercially available and is currently being
manufactured and distributed.  Please discuss the status of all your  products and services.

Robertson J. Orr
Bollente Companies, Inc.
September 20 , 2016
Page 2

 Also discuss your manufacturing facilities, sources and availability of raw materials and
the names of principal suppliers.

Management’s Discussion and Analysis of Financial Condition and Results of Operations

2. Quantify the contribution of each of your products and services to your revenues.
Discuss any trends or uncertainties in the sales or costs of your products and services for
the periods discussed.

3. Please discuss the drivers behind any material changes in your resea rch and development
expenses .  We note tha t your research and development  expenses  significantly decreased
in the amount of $558,057 from the fiscal year ended December 31, 2014 to the fiscal
year ended December 31, 2015 .

4. We note your references to loss o n debt conversion.  Please expand your discussion to
clarify  how the amount was determined.

5.  Disclose the amount paid in royalties to unit holders for the periods being presented.

Exhibits

6. Please file all exhibits required by Item 601 of Regulation S -K.  We note that you did not
file a number of exhibits including your articles of incorporation, bylaws, and a list of
subsidiaries.  We further note that you have not filed several material contracts, including
the following:

 Consulting and employment ag reements ;
 The manufacturer incentive agreement with Meritage Homes Corporation ;
 Property leases, including with a related party ;
 Debt agreements, including with related parties ; and
 Unit purchase agreements entitling investors to royalty interests in the g ross margin
of product sold by Bollente International, Inc.

Form 10 -Q for Fiscal Quarter Ended June 30, 2016

Management’s Discussion and Analysis of Financial Condition a nd Results of Operations

7. Please disclose the conversion terms of the secured convertible promissory note s and
warrants  outstanding as of June 30, 2016 and the convertible promissory note under the
secured loan agreement  executed on August 2, 2016 .

Robertson J. Orr
Bollente Companies, Inc.
September 20 , 2016
Page 3

 Exhibits

8. Please file  the secured convertible promissory notes and warrant s financin g agreement
outstanding as of June 30, 2016  and the secured loan agreement and warrant agreement
executed on August 2, 2016  as exhibits .

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain th at the filing includes the information the Securities Exchange Act of
1934 and all applicab le Exchange Act rules require.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission  or any person under the federal securities laws of the United States.

You may contact Christie Wong, Senior Sta ff Accountant, at (202) 551 -3684  or Joseph
Cascarano, Senior Sta ff Accountant, at (202) 551 -3376  if you have questions regarding our
comment s on the financial statements and related matters.  Please contact Lahdan Rahmati, Law
Clerk, at (202) 551 -8199, or Kathleen Krebs, Special Counsel, at (202) 551 -3350, or me at (202)
551-3810 with any other questions.

Sincerely,

/s/ Larry Spirgel

Larry Spirgel
Assistant Director
AD Office 11 - Telecommunications