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August 14, 2020
Michael Quaid
Chief Executive Officer
Boomer Holdings Inc.
8670 W. Cheyenne Avenue
Las Vegas, NV 89129
Re:Boomer Holdings Inc.
Amendment No. 3 to Registration Statement on Form S-1
Filed August 5, 2020
File No. 333-237087
Dear Mr. Quaid:
            We have reviewed your registration 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 registration 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 registration statement and the information you
provide in response to these comments, we may have additional comments.
Amendment No, 3 to Form S-1
Notes to Unaudited Condensed Consolidated Financial Statements
13. Subsequent Events, page 33
1.We note you disclose there are 139,213,311 common shares outstanding on August 4,
2020 which is more than the combination of common shares outstanding of 128,513,739
at April 30, 2020 and the 7,743,156 shares disclosed as issued on July 20, 2020. Please
reconcile the difference in these amounts for us and provide disclosure of any other
common stock issued after April 30, 2020.
            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.

 FirstName LastNameMichael Quaid
 Comapany NameBoomer Holdings Inc.
 August 14, 2020 Page 2
 FirstName LastName
Michael Quaid
Boomer Holdings Inc.
August 14, 2020
Page 2
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Brian McAllister, Staff Accountant, at 202-551-3341 or Craig
Arakawa, Accounting Branch Chief, at 202-551-3650 if you have questions regarding comments
on the financial statements and related matters.  Please contact Irene Barberena-Meissner,
Staff Attorney, at 202-551-6548 or, in her absence, Timothy S. Levenberg, Special Counsel, at
202-551-3707 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       Peter Campitiello, Esq.