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SEC Company Response from Onar Holding Corp (ONAR) (CIK 0001682265) (ONAR) — Jan 30, 2017

Onar Holding Corp (ONAR) (CIK 0001682265)
Date: Jan. 30, 2017 · CIK: 0001682265 · Accession: 0001580695-17-000076

AI Filing Summary & Sentiment

File numbers found in text: 333-214274

Referenced dates: January 11, 2017, January 23, 2017

Date
January 30, 2017
Author
Assistant Director
Form
CORRESP
Company
Onar Holding Corp (ONAR) (CIK 0001682265)

Letter

Office of Manufacturing and Construction Division of Corporate Finance Re: Reliant Holdings, Inc. Amendment No. 2 to Registration Statement on Form S-1 Filed January 13, 2017 File No. 333-214274

Dear Ms. Long:

On behalf of Reliant Holdings, Inc., a Nevada corporation (the “Company”), we are providing the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) the below responses to the Staff’s comment letter dated January 23, 2017, relating to the Company’s Registration Statement on Form S-1/A Amendment No. 2 (File No. 333-214274) (the “Registration Statement”) filed with the Commission on January 13, 2017, in connection with the registration for resale of 3,585,000 shares of the Company’s common stock (“Common Stock”) by the selling stockholders named in the Registration Statement (collectively, the “Selling Stockholders”).

In connection with these responses the Company is filing an Amendment No. 3 to the Registration Statement on Form S-1 (“Amendment No. 3”) via EDGAR.

The Company’s responses to the Staff’s comments are indicated below, directly following a restatement of each comment in bold type.

Ms. Pamela Long

January 30, 2017

Page 2 of 2

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

1. We note your response to comment 4 in our letter dated January 11, 2017 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.

RESPONSE:

The Company has updated its discussions and descriptions under Results of Operations in Amendment No. 3 to discuss the specific reasons for the changes in its operating results as you have requested and has expanded significantly its descriptions for material line items, costs of sales, and the reasons for the changes in revenue, period-over-period.

Yours very truly,

/s/ John S. Gillies

John S. Gillies

Senior Associate

Show Raw Text
CORRESP
1
filename1.htm

January 30, 2017

Ms. Pamela Long

Assistant Director

Office of Manufacturing and Construction

U.S. Securities and Exchange Commission

Mail Stop 4631

Division of Corporate Finance

Washington, D.C. 20549

    Re:
    Reliant Holdings, Inc.

    Amendment No. 2 to Registration Statement on Form S-1

    Filed January 13, 2017

    File No. 333-214274

Dear Ms. Long:

On behalf of Reliant Holdings,
Inc., a Nevada corporation (the “Company”), we are providing the staff (the “Staff”) of the
Securities and Exchange Commission (the “Commission”) the below responses to the Staff’s comment letter
dated January 23, 2017, relating to the Company’s Registration Statement on Form S-1/A Amendment No. 2 (File No. 333-214274)
(the “Registration Statement”) filed with the Commission on January 13, 2017, in connection with the registration
for resale of 3,585,000 shares of the Company’s common stock (“Common Stock”) by the selling stockholders
named in the Registration Statement (collectively, the “Selling Stockholders”).

In connection with these
responses the Company is filing an Amendment No. 3 to the Registration Statement on Form S-1 (“Amendment No. 3”)
via EDGAR.

The Company’s responses
to the Staff’s comments are indicated below, directly following a restatement of each comment in bold type.

Ms. Pamela Long

January 30, 2017

Page 2 of 2

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

1.        We
note your response to comment 4 in our letter dated January 11, 2017 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.

 RESPONSE:

The Company has updated
its discussions and descriptions under Results of Operations in Amendment No. 3 to discuss the specific reasons for the changes
in its operating results as you have requested and has expanded significantly its descriptions for material line items, costs of
sales, and the reasons for the changes in revenue, period-over-period.

    Yours very truly,

    /s/ John S. Gillies

    John S. Gillies

    Senior Associate