SecProbe.io

CORRESP
 1
 filename1.htm

 CirTran
Corporation

 6360
S Pecos Road, Suite 8

 Las
Vegas, NV 8912

 January
14, 2026

 Division
of Corporate Finance

 U.S.
Securities and Exchange Commission

 100
F Street, N.E.

 Washington,
D.C. 20549

 Re:
 CirTran
 Corp.

 Registration
 Statement Form S-1 – Acceleration Request

 File
 No. 333-292591

 Dear
Sirs and/or Madam:

 This
letter serves as our request, in accordance with Rule 461, for acceleration of the effectiveness of the above-referenced Registration
Statement, as amended, (filed pursuant to Form S-1) to January 16, 2026 at 4:00 p.m., or as soon thereafter as practicable. We advise
you, in connection with Rule 460, that no preliminary prospectuses have been distributed.

 In
that respect and in furtherance of our Acceleration Request, we herewith acknowledge that:

 ● Should
 the Commission or the staff, acting pursuant to delegated authority, declare our filing effective,
 it does not foreclose the Commission from taking any action with respect to the filing;

 ● The
 action of the Commission or the staff, acting pursuant to delegated authority, in declaring
 our filing effective, does not relieve NightFood Holdings, Inc. from its full responsibility
 for the adequacy and accuracy of the disclosure in the filing; and

 ● CirTran
 Corp. may not assert staff comments and the Declaration of Effectiveness as a defense in
 any proceeding initiated by the Commission or any person under the federal securities laws
 of the United States.

 Very
truly yours,

 CirTran
Corp.

 /s/
 Iehab Hawatmeh

 Iehab
 Hawatmeh, CEO

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 January 9, 2026

Iehab Hawatmeh
Chief Executive Officer
CIRTRAN CORP
6360 S Pecos Road, Suite 8
Las Vegas, NV 89120

 Re: CIRTRAN CORP
 Registration Statement on Form S-1
 Filed January 6, 2026
 File No. 333-292591
Dear Iehab Hawatmeh:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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.

 Please contact Erin Donahue at 202-551-6063 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>

Mail Stop 3561

July 2, 2018

Via E -mail
Iehab J. Hawatmeh
Chief Executive Officer
CirTran Corporation
4125 South 6000 West
West Valley City, Utah 84128

Re: CirTran Corporation
 Form 10-12G
Filed May 11, 2018
File No. 000 -49654

Dear Mr. Hawatmeh:

We have completed our review of your filing .  We remind you that the company and its
management are responsible for the accuracy and adequacy of the ir disclosure s, notwithstanding
any review, comments, action or absence  of action  by the staff .

Sincerely,

 /s/ Pamela Howell
 for

John Reynolds
Assistant Director
Office of Beverages, Apparel and
Mining

cc: James R. Kruse, Esq.
      Michael Best & Friedrich, LLP

CORRESP
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June
27, 2018

Mr.
John Reynolds, Assistant Director

Office
of Beverages, Apparel and Mining

U.S.
Securities and Exchange Commission

Mail
Stop 3561

100
F Street, NE

Washington,
D.C. 20549

    Re:
    CirTran
    Corporation

    Amendment
    No. 1 to Form 10-12G

    Filed
    June 18, 2018

    File
    No. 000-49654

Dear
Mr. Reynolds:

This
letter is in response to your letter dated June 25, 2018, respecting your review of the Amendment No. 1 to the Form 10, General
Form of Registration of Securities we filed June 18, 2018. Set forth below is your comment followed by our response. Today we
filed an amendment containing the revised disclosure.

Item
7. Certain Relationships and Related Transactions, page 22

    1.
    Please
    update the disclosure in this section as of the most recent financial statements. For instance, we note you have not updated
    the related-party debt information.

    Response:
    We
    have revised the disclosure.

Please
advise if you have questions about the revised disclosure or if additional information would be helpful to your review.

    Sincerely,

    CirTran
    Corporation

    /s/
    Iehab J. Hawatmeh

    Iehab
    J. Hawatmeh

    Chief
    Executive Officer

Corporate
Headquarters

4125
South 6000 West – West Valley City – Utah 84128 – Tel: (801) 963-5112 – Fax: (801) 963-5180

www.cirtran.com

Mail Stop 3561

June 25, 2018

Via E -mail
Iehab J. Hawatmeh
Chief Executive Officer
CirTran Corporation
4125 South 6000 West
West Valley City, Utah 84128

Re: CirTran Corporation
 Amendment No. 1 to Form 10 -12G
Filed June 18, 2018
File No. 000 -49654

Dear Mr. Hawatmeh:

We have reviewed your June 18, 2018 response to our comment letter 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 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 appl y to your facts and circumstances, please tell us why in your response.

After reviewing your response to these comments, we may have additional comments.
Unless we note otherwise, our references to prior comments are to comments in our June 4, 2018
letter.

Item 7.  Certain Relationships and Related Transactions, page 22

1. Please update the disclosure in this section as of the most recent financial statements.
For instance, we note you have not updated the related party debt information.

Iehab J. Hawatmeh
CirTran Corporation
June 25, 2018
Page 2

You may contact Brian McAllister at (202) 551 -3341 or Angela Lumley at (202) 551 -
3398 if you have questions regarding comments on the financial statements and related matters.
Please contact Ronald (Ron) E. Alper at (202) 551 -3329 or Pam Howell at (2 02) 551 -3357 with
any other questions.

Sincerely,

 /s/ Pamela Howell
 for

 John Reynolds
Assistant Director
Office of Beverages, Apparel and
Mining

cc: James R. Kruse, Esq.
      Michael Best & Friedrich, LLP

CORRESP
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June
18, 2018

Mr.
John Reynolds, Assistant Director

Office
of Beverages, Apparel and Mining

U.S.
Securities and Exchange Commission

Mail
Stop 3561

100
F Street, NE

Washington,
D.C. 20549

    Re:
    CirTran
    Corporation

    Form
    10-12G

    Filed
    May 11, 2018

    File
    No. 000-49654

Dear
Mr. Reynolds:

This
letter is in response to your letter dated June 4, 2018, respecting your review of the Form 10, General Form of Registration of
Securities we filed May 11, 2018. Set forth below are your comments followed by our responses. Today we filed an amendment containing
the revised disclosure.

Directors
and Executive Officers, page 16

 1. Please
                                         briefly discuss the specific experience, qualifications, attributes or skills that led
                                         to the conclusion that each director should serve as a director for the company in light
                                         of the company’s business and structure, as required by Item 401(e)(1) of Regulation
                                         S-K.

 Response: We
                                         have revised the disclosure.

Summary
Compensation Table, page 17

 2. Please
                                         revise the table to include the amount that Mr. Hawatmeh earned in 2017 as salary and
                                         bonus but that has been accrued, as required by Item 402(n)(2)(iii) of Regulation S-K.
                                         See Instruction 4 to Item 402(n).

Corporate
Headquarters

4125
South 6000 West – West Valley City – Utah 84128 – Tel: (801) 963-5112 – Fax: (801) 963-5180

www.cirtran.com

CirTran
                                         Corporation

Mr.
John Reynolds, Assistant Director

Office
of Beverages, Apparel and Mining

U.S.
Securities and Exchange Commission

June
18, 2018

Page
2

    Response:
    Mr.
    Hawatmeh did not accrue any amounts for salary and bonus for the fiscal year ending December 31, 2017. However, for the year,
    we paid health and dental insurance of $24,170 and a vehicle allowance of $12,000, for total compensation of $36,170.

Item
15. Financial Statements and Exhibits, page 24

 3. Please
                                         update your financial statements to include the interim financial statements for the
                                         period ended March 31, 2018. See Rule 8-08 of Regulation S-X.

    Response:
    We
    have updated the disclosure; we have not tagged the inserted financial statements and notes.

Please
advise if you have questions about the revised disclosure or if additional information would be helpful to your review.

    Sincerely,

    CirTran
    Corporation

    /s/
    Iehab J. Hawatmeh

    Iehab
    J. Hawatmeh

    Chief
    Executive Officer

Mail Stop 3561

June 4, 2018

Via E -mail
Iehab J. Hawatmeh
Chief Executive Officer
CirTran Corporation
4125 South 6000 West
West Valley City, Utah 84128

Re: CirTran Corporation
 Form 10-12G
Filed May 11, 2018
File No. 000 -49654

Dear Mr. Hawatmeh:

We have reviewed your filing 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 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 tell us why in your r esponse.

After reviewing your response and any amendment you may file in response to these
comments, we may have additional comments.

Directors and Executive Officers, page 16

1. Please briefly discuss the specific experience, qualification s, attributes or skills that led to
the conclusion that each director should serve as a director for the company in light of the
company’s business and structure, as required by Item 401(e)(1) of Regulation S -K.

Summary Compensation Table, page 17

2. Please  revise the table to include the amount that Mr. Hawatmeh earned in 2017 as salary
and bonus but that has been accrued, as required by Item 402(n)(2)(iii) of Regulation
S-K.  See Instruction 4 to Item 402(n).

Iehab J. Hawatmeh
CirTran Corporation
June 4, 2018
Page 2

 Item 15. Financial Statements and Exhibi ts, page 24

3. Please update your financial statements to include the interim financial statements for the
period ended March 31, 2018.  See Rule 8 -08 of Regulation S -X.

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.

You may contact Brian McAllister at (202) 551 -3341 or Angela Lumley at (202) 551 -
3398 if you have questions regarding comments on the financ ial statements and related matters.
Please contact Ronald (Ron) E. Alper at (202) 551 -3329 or Pam Howell  at (202) 551 -3357  with
any other questions.

Sincerely,

 /s/ Pamela Howell
 for

 John Reynolds
Assistant Director
Office of Beverages, Apparel and
Mining

cc: James R. Kruse, Esq.
      Michael Best & Friedrich, LLP

January 30, 2015

Mr. Iehab Hawatmeh
Chief Executive Officer and
Chairman of the Board of Directors
CirTran Corporation
4125 South 6000 West
West Valley City, Utah 84128

Re: CirTran  Corporation
Form Schedule 14A
Filed October 27, 2014
File No. 000-49654

Dear Mr. Hawatmeh :

We have completed our review of your filing .  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or 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.  We u rge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

 /s/ Pamela Howell
 for

John Reynolds
Assistant Director

cc: James R. Kruse, Esq.
 Kruse Landa Maycock & Ricks, LLC

CORRESP
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     CORRESPONDENCE

January
20, 2015

VIA
EDGAR

John
Reynolds, Assistant Director

Division
of Corporation Finance

U.S.
Securities and Exchange Commission

100
F Street NE

Washington,
DC 20549

    Re:
    CirTran
    Corporation

    Schedule
    14A filed October 27, 2014

    File
    No. 000-49654

Dear
Mr. Reynolds:

This
letter is in response to your letter dated November 14, 2014, respecting your review of the Preliminary Information Statement
on Schedule 14A filed October 27, 2014, by CirTran Corporation (the “Company”).

Set
forth below are your comments, followed by the Company’s responses. The Company incorporated revised disclosures in response
to your comments in its revised Preliminary Information Statement on Schedule 14A/R, which was filed today with revisions marked.

Preliminary
Information Statement on Schedule 14A

Proposal
No. 1, page 5

    1.
    We
    note that you have combined in Proposal No. 1 the reverse stock split and the reduction in the amount of common stock that
    is authorized. Rule 14a-4(a)(3) requires you to clearly identify each separate matter upon which you intend to act, whether
    or not related to or conditioned on the approval of other matters. Please revise to unbundle Proposal No. 1. If any of the
    proposals are mutually conditioned, please revise the proxy statement accordingly and provide appropriate disclosure regarding
    the effect of a negative vote on the related proposals.

    Response:
    The
    reverse stock split and the reduction in the authorized capitalization have been bifurcated as separate issues, with the reduced
    authorization to be considered only if the reverse stock split is approved.

Corporate
Headquarters

4125
South 6000 West – West Valley City – Utah 84128 – Tel: (801) 963-5112 – Fax: (801) 963-5180

www.cirtran.com

CirTran
Corporation

John
Reynolds, Assistant Director

Division
of Corporation Finance

U.S.
Securities and Exchange Commission

January
20, 2015

Page
2

    2.
    We
    note on page 7 that the “formula for calculating the shares to be issued in connection with conversions of these securities
    varies, based on the market price of its common stock” and that there will be “no limitation on the number of
    shares of common stock that may be issued in connection with conversion” if the recapitalization plan is effected. We
    also note on page 8 that there are “conversion limitations, or caps.” Please revise to provide further disclosure
    regarding the conversion feature of the note, including your estimation of the total number of shares that YA Global Investments,
    L.P. (“YA Global”), will receive based upon a range of market prices and the potential profit. Similarly, provide
    clear disclosure of the potential shares that may be issued upon exercise of the warrants and any other payments in stock
    related to this transaction. Discuss the dilutive effect the issuance of common stock upon conversion will have upon investors
    and the downward pressure on stock market price.

    Response:
    Substantial
    new disclosure has been added.

    3.
    Please
    provide tabular disclosure of payments (including the value of any payments to be made in common stock) in connection with
    the transaction that you have made or may be required to make to YA Global, or any affiliates, regarding the transaction (including
    any interest payments, liquidated damages, payments made to “finders” or “placement agents,” and any
    other payments or potential payments). Please provide footnote disclosure explaining each payment and any assumptions used
    in making these calculations. Please do not include any repayment of principal on the convertible notes in this disclosure.

    Response:
    The Company confirms
    that respecting the transactions between YA Global and its affiliates, on the one hand, and the Company and its affiliates,
    on the other, it has not made or agreed to make in the future any payments in cash, stock, or in kind to “finders”
    or “placement agents,” any other payments, or potential payments (including any liquidated damages). The tables
    inserted at pages 6 through 8 set forth the details of all payments to YA Global and its affiliates. In connection with forbearance
    and ratification agreements, the Company reimbursed YA Global for attorney’s fees and other costs of the negotiations
    and documentation as noted in the enhanced disclosure.

    4.
    Please
    provide us, with a view toward disclosure in the proxy statement, with tabular disclosure of all prior securities transactions
    between the issuer (or any of its predecessors) and YA Global, any affiliates of YA Global, or any person with whom YA Global
    has a contractual relationship regarding the transaction (or any predecessors of those persons), with the table including
    the following information disclosed separately for each transaction:

 ● the
                                         date of the transaction;

CirTran
Corporation

John
Reynolds, Assistant Director

Division
of Corporation Finance

U.S.
Securities and Exchange Commission

January
20, 2015

Page
3

 ● the
                                         number of shares of the class of securities subject to the transaction that were outstanding
                                         prior to the transaction;

 ● the
                                         number of shares of the class of securities subject to the transaction that were outstanding
                                         prior to the transaction and held by persons other than YA Global, affiliates of the
                                         company, or affiliates of YA Global;

 ● the
                                         number of shares of the class of securities subject to the transaction that were issued
                                         or issuable in connection with the transaction;

 ● the
                                         percentage of total issued and outstanding securities that were issued or issuable in
                                         the transaction (assuming full issuance), with the percentage calculated by taking the
                                         number of shares issued and outstanding prior to the applicable transaction and held
                                         by persons other than YA Global, affiliates of the company, or affiliates of YA Global,
                                         and dividing that number by the number of shares issued or issuable in connection with
                                         the applicable transaction;

 ● the
                                         market price per share of the class of securities subject to the transaction immediately
                                         prior to the transaction (reverse split adjusted, if necessary); and

 ● the
                                         current market price per share of the class of securities subject to the transaction
                                         (reverse split adjusted, if necessary).

    Response:
    Substantial
    new disclosure has been added.

    5.
    Please
    discuss in greater detail the current status of the convertible debentures and the company’s ability to pay the obligations
    under the convertible debentures.

    Response:
    Substantial
    new disclosure has been added.

General

    6.
    Please revise
    to include a beneficial ownership table. See Item 6(d) of Schedule 14A and Item 403 of Regulation S-K.

    Response:
    The principal stockholder table has been included.

CirTran
Corporation

John
Reynolds, Assistant Director

Division
of Corporation Finance

U.S.
Securities and Exchange Commission

January
20, 2015

Page
4

The Company
acknowledges the following:

 ● 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
                                         Securities and Exchange Commission from taking any action with respect to the filing.

 ● The
                                         Company may not assert staff comments as a defense in any proceeding initiated by the
                                         Securities and Exchange Commission or any person under the federal securities laws of
                                         the United States.

The Company
would be happy to provide additional information you may request or respond to further inquiries.

    Sincerely,

    CirTran Corporation

    /s/ Iehab Hawatmeh

    Iehab Hawatmeh

    Chief Executive
    Officer

cc:
Hillary Daniels

November 14 , 2014

Iehab Hawatmeh
Chief Executive Officer
CirTran Corporation
4125 South 6000 West
West Valley City, Utah 84128

Re: CirTran Corporation
 Form Schedule 14A
Filed October 27, 2014
File No. 000-49654

Dear Mr. Hawatmeh :

We have limited our review of your filing to those issues we have addressed in our
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 within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   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 filing and the information you provide in
response to these comments, we may have  additional comments.

Proposal No. 1, page 5
1. We note that you have combined in Proposal No. 1 the reverse stock split and the
reduction in the amount of common stock that is authorized.  Rule  14a-4(a)(3) requires
you to  clearly identify each separate matter upon which you intend to act, whether or not
related to or conditioned on the approval of other matters.  Please revise to unbundle
Proposal No. 1.  If any of the proposals are mutually conditioned, please revise the proxy
statement accordingly and provide appropriate disclosure regarding the effect of a
negative vote on the related proposals.

2. We note on page 7 that the “formula for calculating the shares to be issued in connection
with conversions of these securities  varies, based on the market price of its common
stock” and that there will be “no limitation on the number of shares of common stock that
may be issued in connection with conversion” if the recapitalization plan is effected.  We
also note on page 8 that t here are “conversion limitations, or caps.”  Please revise to
provide further disclosure regarding the conversion feature of the note, including your

Iehab Hawatmeh
 CirTran Corporation
 November 14 , 2014
 Page 2

 estimation of the total number of shares that YA Global Investments, L.P.  (“YA
Global”) , will receive base d upon a range of market prices and the potential profit.
Similarly, provide clear disclosure of the potential shares that may be issued upon
exercise of the warrants and any other payments in stock related to this transaction.
Discuss the dilutive effec t the issuance of common stock upon conversion will have upon
investors and the downward pressure on stock market price.

3. Please provide tabular disclosure of payments (including the value of any payments to be
made in common stock) in connection with the transaction that you have made or may be
required to make to YA Global, or any affiliates , regarding the transaction (including any
interest payments, liquidated damages, payments  made to “finders” or “placement
agents,” and any other payments or potential  payments).  Please provide footnote
disclosure explaining each payment and any assumptions used in making these
calculations.  Please do not include any repayment of principal on the convertible notes in
this disclosure.

4. Please provide us, with a view to ward disclosure in the proxy statement , with tabular
disclosure of all prior securities transactions between the issuer (or any of its
predecessors) and YA Global, any affiliates of YA Global, or any person with whom YA
Global has a contractual relationshi p regarding the transaction (or any predecessors of
those persons), with the table including the following information disclosed separately for
each transaction:
• the date of the transaction;

• the number of shares of the class of securities subje ct to the transaction that were
outstanding prior to the transaction;

• the number of shares of the class of securities subject to the transaction that were
outstanding prior to the transaction and held by persons other than YA Global,
affiliates of the company, or affiliates of YA Global;

• the number of shares of the class of securities subject to the transaction that were
issued or issuable in connection with the transaction;

• the percentage of total issued and outstanding securities that were iss ued or issuable
in the transaction (assuming full issuance), with the percentage calculated by
taking the number of shares issued and outstanding prior to the applicable
transaction and held by persons other than YA Global, affiliates of the company,
or affiliates of YA Global, and dividing that number by the number of shares
issued or issuable in connection with the  applicable transaction;

• the market price per share of the class of securities subject to the transaction
immediately prior to the transact ion (reverse split adjusted, if necessary); and

Iehab Hawatmeh
 CirTran Corporation
 November 14 , 2014
 Page 3

• the current market price per share of the class of securities subject to the transaction
(reverse split adjusted, if necessary).
5. Please discuss in greater detail the current status of the convertible deb entures and the
company’s ability to pay the obligations under the convertible debentures.
General
6. Please revise to include a beneficial ownership table.  See Item 6(d) of Schedule 14A and
Item 403 of Regulation S -K.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the compa ny 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 co mpany
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.

Please contact Hillary Daniels  at (202) 551 -3959  or me at (202) 551-3357  with any other
questions.

Sincerely,

 /s/ Pamela Howell
 for

 John Reynolds
Assistant Director

cc: James R. Kruse, Esq.
 Kruse Landa Maycock & Ricks, LLC

Mail Stop 6010

       March 1, 2007

Iehab Hawatmeh
President and Director
CirTran Corporation
4125 South 6000 West
West Valley City, Utah 84128

Re:  CirTran Corporation
Revised Preliminary Information Statement
Filed February 26, 2007
File No. 0-49654

Dear Mr. Hawatmeh:

 We have limited our review of your filing to those issues we have addressed in
our comment.  Where indicated, we think you should revise your document in response to
this comment.  If you disagree, we will cons ider your explanation as to why our comment
is inapplicable or a revision is unnecessary.  Please be as detailed as necessary in your
explanation.

Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Special Factors Regarding the Transaction, page 16
1. We note your response to comment 1.  It appears that you have  solicited consents
in violation of Rule 14a-3 to the federa l proxy rules, which require you to furnish
a “publicly filed preliminary or definitiv e written proxy statement” in connection
with the solicitation of proxies (which  includes consents), except in narrow
circumstances.  While it is true that Regulation 14C provides for the use of an
information statement, that use is predicat ed on the initial solicitation of consents
in a manner that is consistent with the federal proxy rules.  See Rules 14a-2 and 14a-3 and the definitions of “solicitat ion” and “proxy.”  Please advise why you
believe you are in compliance with the so licitation requirements of the federal
proxy rules, or explain what steps you w ill take to correct your noncompliance.

CirTran Corporation
March 1, 2007
Page 2
As appropriate, please revise your filing and respond to these comments within 10
business days or tell us when you will provide  us with a response.  You may wish to
provide us with marked copies of the revised filing to expedite our review.  Please furnish
a cover letter with your amendment that keys your responses to our comments and provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing your
amendment and responses to our comments.

Please contact Tom Jones at (202) 551- 3602 or me at (202) 551-3800 with any
questions.

       S i n c e r e l y ,

       Peggy Fisher
       A s s i s t a n t  D i r e c t o r

Mail Stop 6010

February 15, 2007

Iehab Hawatmeh
President and Director
CirTran Corporation
4125 South 6000 West
West Valley City, Utah 84128

Re:  CirTran Corporation
Preliminary Information Statement
Filed February 7, 2007
File No. 0-49654

Dear Mr. Hawatmeh:

 We have limited our review of your filing to  those issues we have addressed in our
comments.  Where indicated, we think you should revise your document in response to these
comments.  If you disagree, we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed as necess ary in your explanation.
In some of our comments, we may ask you to pr ovide us with information so we may better
understand your disclosure.  After reviewing this information, we may raise additional comments.

Please understand that the purpose of our review process is to  assist you in your compliance
with the applicable disclosure requirements and to enhance the ove rall disclosure in your filing.
We look forward to working with you in these re spects.  We welcome any questions you may have
about our comments or on any other aspect of our review.  Feel free to ca ll us at the telephone
numbers listed at the end of this letter.

General
1. It appears that your so licitation to obtain the consents of holders of a majority of your
shares did not comply with Rule 14a-3(a) of  Regulation 14A.  Please provide your analysis
to support your position that th e consents were obtained in compliance with the proxy rules.

Board of Directors Meeti ngs, Committees and Director Compensation, page 17
2. Please update this section to in clude required disclosure for th e fiscal year ended December
31, 2006 and the new executive compensation disc losure rules.  See Release No. 33-8765,
which is available on our website.

CirTran Corporation
February 15, 2007
Page 2
As appropriate, please revise your filing and respond to these comments within 10 business
days or tell us when you will provide us with a response.  You may wish to provide us with marked copies of the revised filing to expedite our review.  Please furnish a cover letter with your amendment that keys your res ponses to our comments and provide s any requested information.
Detailed cover letters greatly facilitate our revi ew.  Please understand that  we may have additional
comments after reviewing your amendmen t and responses to our comments.

  We urge all persons who are responsible for the accuracy and adequacy of the disclosure in
the proxy statement to be certain that the fi ling includes all information required under the
Securities Exchange Act of 1934 and that they have  provided all informati on investors require for
an informed investment decision.  Since the comp any and its management are in possession of all
facts relating to a company’s disclosure, they ar e responsible for the accur acy and adequacy of the
disclosures they have made.

 In connection with responding to our comme nts, please provide, in writing, a statement
from the company acknowledging that:

‚ the company is responsible for the adequacy and accuracy of the disclo sure in the filing;

‚ staff comments or changes to disclosure in re sponse 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.

In addition, please be advised th at the Division of Enforcement has access to all information
you provide to the staff of the Division of Corpor ation Finance in our review of your filing or in
response to our comments on your filing.

Please contact Tom Jones at (202) 551-3602 or me at (202) 551-3800 if you have questions.

       S i n c e r e l y ,

       Peggy Fisher
       A s s i s t a n t  D i r e c t o r