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December 9, 2020
Jan Goetgeluk
Chief Executive Officer
Virtuix Holdings Inc.
1826 Kramer Lane, Suite H
Austin, TX 78758
Re:Virtuix Holdings Inc.
Amendment No. 4 to
Offering Statement on Form 1-A
Filed November 27, 2020
File No. 024-11309
Dear Mr. Goetgeluk:
            We have reviewed your amended offering statement and have the following
comment.  In our comment, 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 comment applies 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 this comment, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our November 25, 2020 letter.
Amendment No. 4 to Form 1-A
General
1.We note on the powerpoint presentation on the SeedInvest website that your gross margin
for the year ended March 31, 2020 was approximately 50%; however, your gross margin
is disclosed in your offering memorandum as approximately 23%.  Please advise or revise.

            You may contact Eiko Yaoita Pyles, Staff Accountant, at (202) 551-3587 or Christine

 FirstName LastNameJan Goetgeluk
 Comapany NameVirtuix Holdings Inc.
 December 9, 2020 Page 2
 FirstName LastName
Jan Goetgeluk
Virtuix Holdings Inc.
December 9, 2020
Page 2
Dietz, Senior Staff Accountant, at (202) 551-3408 if you have questions regarding comments on
the financial statements and related matters. Please contact Michael C. Foland, Attorney-
Advisor, at (202) 551-6711 or Larry Spirgel, Office Chief, at (202) 551-3815 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Andrew Stephenson