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CORRESP
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 Elventix
Technology Corporation

 1309 Coffeen
Avenue STE 1200 Sheridan, Wyoming 82801

 December 4, 2025

 The United States Securities

 and Exchange Commission

 U.S. Securities & Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, DC 20549

 Re: 	 Elventix Technology Corporation

 Acceleration
Request for Registration Statement on Form S-1 (No. 333-289122)

 Dear Ladies
and Gentlemen ,

 Pursuant to Rule 461 promulgated under the Securities
Act of 1933, as amended, Elventix Technology Corporation (the "Registrant") hereby requests acceleration of the effective
date of its Registration Statement on Form S-1 ( No. 333-289122 ), as amended (the "Registration
Statement"), so that it may become effective at 12:00 p.m. Eastern Daylight Time on December 8, 2025, or as soon as practicable
thereafter.

 The Registrant confirms that it is aware of its obligations
under the Act.

 The Registrant hereby acknowledges that:

 (i) should the Securities and Exchange Commission
(the "Commission") or the staff, acting pursuant to delegated authority, declare the Registration Statement effective,
it does not foreclose the Commission from taking any action with respect to the Registration Statement;

 (ii) the action of the Commission or the staff,
acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full
responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

 (iii) the Registrant may not assert comments
of the Commission or the staff and the declaration of effectiveness of the Registration Statement as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.

 Sincerely,

 ELVENTIX TECHNOLOGY CORPORATION

 By:
 /s/
 Tallis Mateus Da Silva

 Name:
 Tallis Mateus Da Silva

 Title:
 President, Director, Treasurer and Secretary

 (Principal Executive, Financial and Accounting Officer)

 By:
 /s/
 Jose Alejandro Bejarano Velasquez

 Name:
 Jose Alejandro Bejarano Velasquez

 Title:
 Director

November 18, 2025
Tallis Mateus Da Silva
Principal Executive Officer
Elventix Technology Corporation
1309 Coffeen Avenue Suite 1200
Sheridan, Wyoming 82801
Re:Elventix Technology Corporation
Amendment No. 2 to Registration Statement on Form S-1
Filed October 15, 2025
File No. 333-289122
Dear Tallis Mateus Da Silva:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a 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 registration statement and the information
you provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our September 29, 2025
letter.
Amendment No. 2 to Registration Statement on Form S-1
Interim Financial Statements as of August 31, 2025
Statements of Cash Flows, page F-5
1.Please revise "the net cash increase for period" and "cash at end of period" line items
to reflect the correct amounts  of ($2,097) and $403, respectively.

November 18, 2025
Page 2
Notes to the Financial Statements as of and for the period ended May 31, 2025
Note 3. Summary of Significant Accounting Policies
Dividends, page F-6
2.You state here that the promissory note to Smarterest Incorporated matures on
November 15, 2025. However, on pages 11 and 27 you refer to a maturity date of
November 14, 2026. Please revise this apparent inconsistency. To the extent the
agreement has been subsequently revised, ensure you include a discussion of such
change in a subsequent events footnote and file such amendment as an exhibit.
            Please contact Megan Masterson at 202-551-3407 or Kathleen Collins at 202-551-
3499 if you have questions regarding comments on the financial statements and related
matters. Please contact Alexandra Barone at 202-551-8816 or Kathleen Krebs at 202-551-
3350 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology

September 29, 2025
Tallis Mateus Da Silva
Principal Executive Officer
Elventix Technology Corporation
1309 Coffeen Avenue Suite 1200
Sheridan, Wyoming 82801
Re:Elventix Technology Corporation
Amendment No. 1 to Registration Statement on Form S-1
Filed September 18, 2025
File No. 333-289122
Dear Tallis Mateus Da Silva:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a 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 registration statement and the information
you provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our August 26, 2025 letter.
Amendment No. 1 to Registration Statement on Form S-1
Risk Factors
We are solely dependent upon the funds to be raised in this offering..., page 11
1.We note your response to prior comment 20. You continue to state here that the
estimated cost of this registration statement will be paid from offering proceeds, while
in another risk factor on page 18 you state you will utilize funds from your CEO and
directors to pay such expenses, and on page 63 you state some expenses may be paid
from the offering proceeds, but the majority have been and are expected to be funded
from existing funds provided by the director. Please revise to reconcile these
inconsistencies. To the extent such expenses will be paid (or repaid) out of the
proceeds of this offering, ensure your disclosures throughout reflect proceeds, net of
such expenses.

September 29, 2025
Page 2
Dilution, page 23
2.We note there continues to be numerous errors in your revised dilution disclosures in
response to prior comment 8. Please address the following:
•Revise your discussion of net tangible book value in the introductory paragraphs
to state that net tangible book value is the amount that results from subtracting
total liabilities from total tangible assets.
•Revise the introductory paragraph to refer to the correct net tangible book value
amount at May 31, 2025 of ($208,237).
•Revise to include the correct amount of post offering net tangible book value in
the table under the 20%, 50% and 75% scenarios. In this regard, your current
disclosure ($208,237) refers to the net tangible book value before offering.
•Ensure the percentage dilution noted under the 20%, 50% and 75% scenarios
reflects the dilution per share to new investors as a percentage of the offering
price.
•Revise the amount of anticipated net proceeds line item under the 20%, 50% and
75% scenarios, as your current reference to $0 is not correct.
•Ensure the percentage of both purchasers and existing shareholders totals 100%.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Plan of Operation, page 25
3.We note your response to prior comment 9. Please expand your disclosure to
distinguish how each level and use of proceeds will achieve specific services and key
features and functionalities described in the description of your business.
Liquidity and Capital Resources, page 26
4.We note your response to prior comment 10 and your revised disclosures regarding
the amended loan agreement with your CEO. Please further revise to disclose the
terms of the promissory note payable issued in exchange for the Smarterest app. Also,
revise to clarify whether you intend to use any proceeds from this offering to repay
the loan with your CEO. In addition, revise your risk factor on page 10 to include a
discussion of the amended loan agreement.
5.We note your response to prior comment 11. Please disclose with specificity the level
of your proposed operations you could achieve after paying expenses.
Description of Business
Future Plans, page 34
6.Please expand your disclosure to clarify the costs accompanying each proposed step
of your future plan.

September 29, 2025
Page 3
Report of Independent Registered Public Accounting Firm, page F-1
7.We note subsequent events have been updated through September 18, 2025. In
addition, Note 3 has been revised to include information about your promissory note
payable and Note 5 has been updated to discuss the amendment to the related party
loan that occurred subsequent to year end. Please request your auditors to dual-date
their report for these events. Refer to AS 3110.05.
            Please contact Megan Masterson at 202-551-3407 or Kathleen Collins at 202-551-
3499 if you have questions regarding comments on the financial statements and related
matters. Please contact Alexandra Barone at 202-551-8816 or Kathleen Krebs at 202-551-
3350 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Carl P. Ranno, Esq.

August 26, 2025
Tallis Mateus Da Silva
Principal Executive Officer
Elventix Technology Corporation
1309 Coffeen Avenue Suite 1200
Sheridan, Wyoming 82801
Re:Elventix Technology Corporation
Registration Statement on Form S-1
Filed July 31, 2025
File No. 333-289122
Dear Tallis Mateus Da Silva:
            We have reviewed your registration statement and have the following comments.
            Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a 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 registration statement and the information
you provide in response to this letter, we may have additional comments.
Registration Statement on Form S-1
Cover Page
1.Please disclose prominently on the cover page and in the prospectus summary that
Tallis Mateus Da Silva, your sole officer and shareholder, currently owns 100% of
your common shares, will continue to own a majority of your shares after the offering
and will have effective control over the company. Include a cross-reference to the
related risk factor disclosure.
The Offering, page 8
2.Please revise the “Securities Offered” line item to indicate that 4,000,000 shares of
common stock are being offered, as disclosed elsewhere throughout the filing.

August 26, 2025
Page 2
Risk Factors, page 10
3.We note that you are an emerging growth company and a smaller reporting company.
Please include disclosure to clarify that you are a smaller reporting company and
provide a risk factor to disclose that even if you no longer qualify as an emerging
growth company, you may still be subject to reduced reporting requirements so long
as you are a smaller reporting company.
Because our officer will only be devoting limited time to our operations..., page 15
4.You indicate that Mr. Da Silva will devote limited time to your operations, but then
state that he will be devoting approximately 40 hours per week to your operations.
Please clarify why you consider 40 hours per week to be insufficient time that may
lead to the risks discussed.
Tallis Mateus Da Silva, our principal stockholder, beneficially owns more than 50% of our
outstanding shares..., page 16
5.Please revise this risk factor to focus on the ability of Mr. Da Silva to control
corporate decisions, transactions and corporate governance through his ownership and
voting control and his potential conflicts of interest with other shareholders. Your
disclosure regarding the company being a "controlled company" does not appear to
apply to the company since the exemptions discussed apply only to companies listed
on an exchange such as Nasdaq.
Our President, Director and Treasurer is a non-U.S. resident..., page 17
6.Please disclose where Mr. Da Silva is a resident and where the company's assets are
located.
We intend to become subject to the reporting requirements of the Securities Exchange Act of
1934..., page 20
7.The purpose of this risk factor is not clear since you are subject to the same audit and
other requirements as a reporting company under Section 15(d). Please revise or
advise.
Dilution, page 22
8.Please revise your historical and pro forma net tangible book value (deficit) and
related net tangible book value per share calculations to exclude your
intangible assets. In addition, ensure the net tangible book value per share line items
reflect per share amounts and not the net tangible book value amounts as you
currently disclose, and revise the remaining line items to appropriately reflect the
resulting change in net tangible book value per share after the offering and dilution
per share.
Plan of Operation, page 24
9.Please expand the discussion of your plan of operations in the twelve months
following completion of the offering to indicate the extent to which each level and use
of proceeds will achieve the services and key features and functionalities described in
the description of your business.

August 26, 2025
Page 3
Liquidity and Capital Resources, page 26
10.Please revise here to include a discussion of the promissory note payable issued in
exchange for the Smarterest app, including its material terms and how you intend to
fund the repayment of such note. In this regard, clarify whether you intend to use any
proceeds from this offering to repay such note or the funds available from the
$200,000 loan with your CEO and Director.
11.You disclose that you require a minimum of $24,000 to conduct your proposed
operations and pay all expenses for a minimum of one year. Please disclose the level
of your proposed operations you could achieve after paying expenses.
Description of Business, page 27
12.Please describe the functionality of the Smarterest app when you purchased it and
whether it was ever commercially available. Discuss the extent to which it was
designed for the features and functionalities the company plans to implement.
13.We note your disclosure about users, your “customer base”, and your “target market”
throughout the registration statement. We also note your disclosure that the company
has no customers. Please expand your disclosure to discuss your target market and
how you intend to grow such market and attract customers and users.
14.You indicate you intend to use artificial intelligence and machine learning in
connection with your mobile application. Please specify whether you intend to use
proprietary or third-party open-source algorithms. Include risk factor disclosure
related to your intended use of artificial intelligence.
Future Plans, page 33
15.Please expand your disclosure to discuss the resources required to complete each step
of your strategic business plans, as well as the challenges you anticipate in
implementing your business plan.
Offices, page 35
16.The address you disclose as your business address appears to be a virtual office
that provides mail forwarding services. Please clarify your disclosure and indicate
where you conduct your business operations.
Directors, Executive Officers, Promoter and Control Persons, page 36
17.Please revise the biography of Mr. Da Silva so that it clearly covers his business
experience for the last five years. For example, it is not clear how long he worked at
Xplora Digital SL before becoming Elventix Technology's officer and director in
March 2025 or whether he still works there or has any other current occupation.

August 26, 2025
Page 4
Description of Securities, page 40
18.Please expand the disclosure of your common stock to discuss voting rights, dividend
rights, terms of conversion, any sinking fund or redemption provisions, liquidation
rights, and preemption rights. Refer to Item 202 of Regulation S-K.
Where You Can Find More Information, page 47
19.Please disclose what reports you will file with the Commission upon effectiveness of
the current registration statement.
Other Expenses of Issuance and Distribution, page 59
20.You state throughout the filing that the estimated cost of this registration statement is
$12,000, however, your table of estimated costs reflects expenses of $6,020. Please
reconcile this apparent inconsistency. In addition, you state on page 10 that the
estimated cost of this registration statement will be paid from offering proceeds, while
on page 17, you state you will utilize funds from your CEO and directors to pay such
expenses. Please revise. To the extent such expenses will be paid out of the proceeds
of this offering, ensure your disclosures throughout reflect proceeds, net of such
expenses.
Financial Statements
Note 3. Summary of Significant Accounting Policies, page F-6
21.Please revise to include a footnote disclosing the terms of the promissory note issued
to Smarterest Incorporated in exchange for the Smarterest mobile app.
Note 5. Related Party Transactions, page F-6
22.You state no shareholders or directors have made a written commitment for continued
support, and any advances were considered temporary and not supported by a
promissory note. Please reconcile this statement with your disclosures
elsewhere, including the loan agreement filed as Exhibit 10.1, whereby Mr. Da Silva
has agreed to provide up to $200,000 of financial support over the next five years, as
needed. Revise as necessary.
            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.
            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.

August 26, 2025
Page 5
            Please contact Megan Masterson at 202-551-3407 or Kathleen Collins at 202-551-
3499 if you have questions regarding comments on the financial statements and related
matters. Please contact Alexandra Barone at 202-551-8816 or Kathleen Krebs at 202-551-
3350 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Carl P. Ranno, Esq.