SecProbe.io

Mail Stop 4631
January 11, 2017

Via E -Mail
Michael Chavez
President
Reliant Holdings, Inc.
12343 Hymeadow Drive, Suite 3 -A
Austin, Texas 78750

Re: Reliant Holdings, Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed December 28 , 2016
  File No. 333 -214274

Dear Mr. Chavez :

We have reviewed your amended 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
circumstanc es 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.

Genera l

1. We note your revised disclosure in response to comment 1 in our letter dated November
22, 2016.  Please disclose in the prospectus the entire supplemental response.

Michael Chavez
Reliant Holdings, Inc.
January 11, 2017
Page 2

 Risk Factors, page  9

Government regulations could increase the cost of our constructi on . . ., page 16

We may incur additional  operating expenses or delays due to . . ., page 17

2. These risk factors appear to cover the same risk.  Please revise your registration statement
to combine these two risk factors.

Government Regulations, page 37

3. We note your revised disclosure in response to comment 14 in our letter dated November
22, 2016.  Please reconcile your disclosure that you do not bear the costs or liability
associated with environmental laws and your disclosure that you build in the cos t of
permitting and compliance with building codes with your risk factor disclosure on page
16 and page 17 that discusses the increased costs and operating expenses you may incur
related to environmental regulations and compliance requirements.

Management ’s Discussion and Analysis of Financial Condition . . ., page 40

4. We note your response to comment 15 in our letter dated November 22, 2016 and we re -
issue our comment.  Please revise your disclosure throughout this section to discuss the
specific reasons for the changes in your operating results so that potential investors gain
better insight into your results, particularly for trend purposes and discerning future
prospects.  By way of example, when discussing your increase in gross margin for the
fiscal y ear ended December 31, 2015, you reference changes in pricing in the prior
period.  It is not clear during which time period you lowered prices and when you raised
your prices.

Exhibit 5.1

5. We note your counsel’s revised legal opinion refers specificall y to Amendment No. 1 to
your registration statement on Form S -1.  Please have counsel revise its opinion to relate
to your next amendment to your registration statement and any potential amendments
thereafter.

Michael Chavez
Reliant Holdings, Inc.
January 11, 2017
Page 3

 You may contact  Tracey McKoy  (Staff Accountan t) at 202-551-3772  or Terence O’Brien
(Accounting Branch Chief ) at 202-551-3355  if you have questions regarding the financial
statements and related matters.  Please contact  Frank Pigott  (Staff Attorney) at 202-551-3570  or
me at 202-551-3729  with any other  questions.

Sincerely,

 /s/ Craig Slivka, for

 Pamela Long
Assistant Director
Office of Manufacturing and
Construction

cc: David M. Loev
 The Loev Law Firm, PC