SecProbe.io

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 January 29, 2026

 VIA EDGAR

 United States Securities and Exchange Commission

 100 F. Street, NE

 Washington, DC 20549

 Division of Corporation Finance

 Attn:
 Alyssa Wall

 Re: GenFlat Holdings, Inc.

 Registration Statement on Form S-1, as amended

 File No. 333-291718

 Ladies and gentlemen:

 Pursuant to Rule 461 of the
General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, Craig Hallum
Capital Group LLC, as Underwriter, hereby requests acceleration of the effective date of the above-referenced Registration Statement so
that it will become effective at 4:00 p.m., Eastern Time, on January 30, 2026, or as soon thereafter as practicable, or
at such later time as the Company or its counsel may request via telephone call to the staff .

 Pursuant to Rule 460 under
the Act, please be advised that we will take reasonable steps to secure adequate distribution of the preliminary prospectus, to underwriters,
dealers, institutions and others, prior to the requested effective time of the Registration Statement.

 The undersigned advises that
it has complied and will continue to comply, and that it has been informed by the participating underwriters and dealers that they have
complied with and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 Thank you,

 CRAIG HALLUM CAPITAL GROUP LLC

 By: /s/ Rick Hartfiel

 Name: Rick Hartfiel

 Title: Head of Investment
Banking

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 GENFLAT HOLDINGS, INC.

 1983 N. Berra Blvd.

 Tooele , Utah 84074

 January 29, 2026

 VIA EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F. Street, N.E.

 Washington, D.C. 20549

 Re: GenFlat Holdings, Inc. (the " Company ")

 Registration Statement on Form S-1

 File No. 333-291718

 Ladies and Gentlemen:

 In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned respectfully requests that the effective date of the above referenced Registration Statement
be accelerated so that the same will become effective at 4:00 PM, Eastern Time, on January 30, 2026, or as soon thereafter as is practicable.

 Very truly yours,

 GenFlat Holdings Inc.

 By: /s/ Drew Hall

 Name: Drew Hall

 Title: Chief Executive Officer

March 19, 2025
Drew D. Hall
Chief Executive Officer and Chief Financial Officer
GenFlat Holdings, Inc.
1983 N Berra Blvd
Tooele, UT 84074
Re:GenFlat Holdings, Inc.
Draft Registration Statement on Form S-1
Submitted March 11, 2025
CIK No. 0001796949
Dear Drew D. Hall:
            This is to advise you that we do not intend to review your registration statement.
            We request that you publicly file your registration statement no later than 48 hours
prior to the requested effective date and time. 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 Alyssa Wall at 202-551-8106 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:David M. Bovi

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Healthcare Business Resources, Inc.

718 Thompson Lane, Suite 108-273

Nashville, Tennessee 37204

September
22, 2020

Division
of Corporation Finance

Securities
and Exchange Commission

100 F
Street, N.E.

Washington,
D.C. 20549

Attention:

Ms. Cara
Wirth

Ms. Mara
Ransom

Re:
    Healthcare Business Resources, Inc.

Form S-1/A

Filed September 8, 2020

File No. 333-239000

 Ladies
and Gentlemen:

At the request of the U.S. Securities and Exchange
Commission (the “Commission”), Healthcare Business Resources,
Inc. (the “Company”) is providing this letter in response to
the comments made in the Commission’s letter dated September
18, 2020. Your comments and the Company’s responses are set
forth below.

Comment No.
1

Please update the
"Promoters and control persons" disclosure to account for the
August 8, 2020 grant of non-qualified stock options to Joel
Arberman. Refer to Item 404(c)(1)(i) of Regulation S-K.
Additionally, please tell us what consideration you gave to
disclosing this option grant in accordance with Item 404(a) of
Regulation S-K and, if applicable, please include the required
disclosure in this section.

Response:

We modified the
text on page 39. The value of the option grant exceeded the
threshold amount in Item 404(d)(1)

Sincerely,

/s/ Stephen Epstein

Stephen
Epstein

Chief
Executive Officer

United States securities and exchange commission logo
September 18, 2020
Stephen Epstein
Chief Executive Officer
Healthcare Business Resources, Inc.
718 Thompson Lane, Suite 108-273
Nashville, Tennessee 37204
Re:Healthcare Business Resources, Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed September 9, 2020
File No. 333-239000
Dear Mr. Epstein:
            We have reviewed your amended registration statement and have the following
comment.  In our comment, 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 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 comment, we may have additional comments.
Amendment No. 2 to Registration Statement on Form S-1 filed September 9, 2020
Transactions with Related Persons, page 30
1.Please update the "Promoters and control persons" disclosure to account for the August 8,
2020 grant of non-qualified stock options to Joel Arberman. Refer to Item 404(c)(1)(i) of
Regulation S-K. Additionally, please tell us what consideration you gave to disclosing this
option grant in accordance with Item 404(a) of Regulation S-K and, if applicable, please
include the required disclosure in this section.

 FirstName LastNameStephen Epstein
 Comapany NameHealthcare Business Resources, Inc.
 September 18, 2020 Page 2
 FirstName LastName
Stephen Epstein
Healthcare Business Resources, Inc.
September 18, 2020
Page 2
            You may contact Aamira Chaudhry at (202) 551-3389 or Lyn Shenk at (202) 551-3380 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Cara Wirth at (202) 551-7127 or Mara Ransom at (202) 551-3264 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Joel Arberman

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Healthcare Business Resources, Inc.

718 Thompson Lane, Suite 108-273

Nashville, Tennessee 37204

September
8, 2020

Division
of Corporation Finance

Securities
and Exchange Commission

100 F
Street, N.E.

Washington,
D.C. 20549

Attention:

Ms. Cara
Wirth

Ms.
Mara Ransom

Re:        Healthcare
Business Resources, Inc.

Form S-1/A

Filed June 13, 2020

File No. 333-239000

 Ladies
and Gentlemen:

At the request of the U.S. Securities and Exchange
Commission (the “Commission”), Healthcare Business Resources,
Inc. (the “Company”) is providing this letter in response to
the comments made in the Commission’s letter dated July 21,
2020. Your comments and the Company’s responses are set forth
below.

Comment No.
1

We re-issue our
prior comment no. 1 in part. Please explain why you believe that
"many

healthcare
organizations face significant operational and financial changes"
and how your

business model
addresses these changes.

Response:

We modified the
text on pages 3 and 26 to state that we focus on healthcare
organizations that face operational and financial changes, rather
than stating that we believe that many healthcare organizations are
facing significant and financial changes.

Comment No.
2

We re-issue our
prior comment no. 8. Please file a written description of the
CEO's

compensatory plan
as an exhibit. Refer to Item 601(b)(10)(iii)(A) of Regulation
S-K.

Response:

We included an
employment agreement for the CEO as Exhibit 10.5 to the Form
S-1/A.

Comment No.
3

We note your
response to our prior comment no. 10. Please revise your risk
factor

disclosure to
include the statements that you made in the "Description of
Securities"

section,
specifically that your exclusive forum selection does not apply to
federal

securities claims,
a court could find the choice of forum provisions to be
inapplicable or

unforeseeable, and
shareholders cannot waive compliance with the federal securities
laws.

Response:

We revised the risk
factor accordingly. Please see the risk factor on page
15.

Additionally,
please be advised that since June 13, 2020, the date of the last
filing of the amended registration statement, that we (i)
re-allocated the ownership of the original founder’s shares
amongst the original founders; (ii) effectuated a 20-for-1 forward stock split of our outstanding
common stock in the form of a stock dividend; all of which
is reflected in this Amendment No. 2 to the registration
statement.

Sincerely,

/s/ Stephen Epstein

Stephen
Epstein

Chief
Executive Officer

United States securities and exchange commission logo
July 21, 2020
Stephen Epstein
Chief Executive Officer
Healthcare Business Resources, Inc.
718 Thompson Lane, Suite 108-273
Nashville, Tennessee 37204
Re:Healthcare Business Resources, Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed July 13, 2020
File No. 333-239000
Dear Mr. Epstein:
            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
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.  Unless we note
otherwise, our references to prior comments are to comments in our July 2, 2020 letter.
Amendment No. 1 to Registration Statement on Form S-1
Prospectus Summary, page 2
1.We re-issue our prior comment no. 1 in part. Please explain why you believe that "many
healthcare organizations face significant operational and financial changes" and how your
business model addresses these changes.
Executive Compensation, page 29
2.We re-issue our prior comment no. 8. Please file a written description of the CEO's
compensatory plan as an exhibit. Refer to Item 601(b)(10)(iii)(A) of Regulation S-K.

 FirstName LastNameStephen Epstein
 Comapany NameHealthcare Business Resources, Inc.
 July 21, 2020 Page 2
 FirstName LastName
Stephen Epstein
Healthcare Business Resources, Inc.
July 21, 2020
Page 2
General
3.We note your response to our prior comment no. 10. Please revise your risk factor
disclosure to include the statements that you made in the"Description of Securities"
section, specifically that your exclusive forum selection does not apply to federal
securities claims, a court could find the choice of forum provisions to be inapplicable or
unforeseeable, and shareholders cannot waive compliance with the federal securities laws.
            Please contact Cara Wirth at (202) 551-7127 or Mara Ransom at (202) 551-3264 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Joel Arberman

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Healthcare Business Resources, Inc.

718 Thompson Lane, Suite 108-273

Nashville, Tennessee 37204

July
13, 2020

Division
of Corporation Finance

Securities
and Exchange Commission

100 F
Street, N.E.

Washington,
D.C. 20549

Attention:

Ms. Cara
Wirth

Ms.
Mara Ransom

Ms.
Aamira Chaudhry

Mr.
Bill Thompson

Re:        Healthcare
Business Resources, Inc.

Form S-1

Filed June 8, 2020

File No. 333-239000

 Ladies
and Gentlemen:

At the request of the U.S. Securities and Exchange
Commission (the “Commission”), Healthcare Business Resources,
Inc. (the “Company”) is providing this letter in response to
the comments made in the Commission’s letter dated July 7,
2020. Your comments and the Company’s responses are set forth
below.

Comment No.
1

We note your
disclosure that states that "[d]istressed companies respond to
challenges by restructuring their business and capital structure,
while healthy companies strive to capitalize on opportunities by
improving operations, reducing costs and maximizing revenue."
Please characterize this as your belief. In doing so, please
elaborate upon the statement that precedes it to explain why you
believe that "many healthcare organizations face significant
operational and financial changes" and how your business model
addresses these changes.

Response:

Please see the
revised disclosure to “Prospectus Summary” on page 2
and “Principal Services” on page 21.

Comment No.
2

Please revise the
footnotes to match the data in the table. For example, footnotes 2,
11 and 13 appear to be missing or incorrect.

Response:

Please see the
revised disclosure to “Selling Stockholders” on page
14.

Comment No.
3

We note that your
beneficial ownership table discloses the holdings of one officer
and two directors, but your beneficial ownership table lists "all
executive officers and directors as a group," as two people. Please
correct this inconsistency. Also, please confirm the number of
shares owned by executive officers and directors as a
group.

Response:

We confirm the
shares owned by executive officers and directors as a group is
801,100. Please see the revised disclosure to “Security
Ownership of Certain Beneficial Owners and Management” on
page 19.

Comment No.
4

We note that your
CEO provides the corporate office space to your company at no
charge. We also note your disclosure on page 26 that states that
operating expenses were used to pay rent. Please revise your
disclosure to clarify this inconsistency. Also, to the extent the
value of the rent that is being forgone by your CEO triggers
applicable disclosure requirements, please disclose this
arrangement in your Certain Relationships and Related Transactions
section.

Response:

Please see the revised
disclosure to “Result of Operations” on page 26,
whereby the reference to the payment of rent was deleted. The value
of the annual rent being foregone is $1,200, which does not meet
the threshold for disclosure under Item 404 of Regulation
S-K.

1

Comment No.
5

Please include
disclosure in the Management's Discussion and Analysis section to
describe and quantify, to the extent possible, any known trends and
uncertainties that have had, or that you reasonably expect will
have, a material impact on your business, revenue or results of
operations due to COVID-19. Refer to Item 303(a) of Regulation SK,
Release No. 33-8350 and CF Disclosure Guidance: Topic No.
9

Response:

Please see the revised
disclosure to “Management’s Discussion and Analysis of
Financial Condition” on page 27.

Comment No.
6

We note your
disclosure that you will be required to estimate the amount of
royalties on an accrual basis under ASU 2014-09. Please tell us why
this disclosure is applicable to your proposed
business

Response:

The disclosure has
been removed. Please
see the revised disclosure to “Management’s
Discussion and Analysis of Financial Condition” on page
27.

Comment No.
7

Your website
indicates that Mr. Epstein is your interim CEO and will perform
such duties until such time as the company retains a CEO and CFO.
Please revise to state as much here and reconcile this disclosure
with your disclosure elsewhere which states that your "prospective
management consulting and financial incentive program
opportunities" will be identified through your CEO's personal and
professional relationships.

Response:

The website has
been updated.

Comment No.
8

We note that you
have a verbal compensatory agreement with your CEO, President and
Chief Financial Officer. Please file a written description of the
compensatory plan as an exhibit. Refer to Item 601(b)(10)(iii)(A)
of Regulation S-K

Response:

Please see the revised
disclosure to “Executive Compensation” on page 29,
whereby the reference to health benefits was removed because there
are no health care plans in place or contemplated to be put in
place in the near future.

Comment No.
9

Please revise to
file a dated consent of your Independent Registered Public
Accounting Firm. Refer to Item 601(b)(23)(i) of Regulation
S-K.

Response:

Please see the revised
Exhibit 23.1

Comment No.
10

We note that the
forum selection provision in your bylaws identifies the Court of
Chancery of the State of Delaware (or, if the Court of Chancery
does not have jurisdiction, the federal district court for the
District of Delaware) as the exclusive forum for certain
litigation, including any “derivative action.” Please
revise your prospectus to provide investors with disclosure about
this provision, including whether this provision applies to actions
under the Securities Act or the Exchange Act. If so, please also
state that there is uncertainty as to whether a court would enforce
such provision. If the provision applies to Securities Act claims,
please also state that investors cannot waive compliance with the
federal securities laws and the rules and regulations thereunder.
In that regard, we note that Section 22 of the Securities Act
creates concurrent jurisdiction for federal and state courts over
all suits brought to enforce any duty or liability created by the
Securities Act or the rules and regulations thereunder. If this
provision does not apply to actions arising under the Securities
Act or Exchange Act, please also ensure that the exclusive forum
provision in the governing documents states this clearly, or tell
us how you will inform investors in future filings that the
provision does not apply to any actions arising under the
Securities Act or Exchange Act.

Additionally, if
the forum selection provision applies to claims made under the
federal securities laws, please revise to include disclosure
regarding the risks or other impacts of the provision on investors,
including but not limited to increased costs to bring a claim and
the potential discouraging of claims or limitation of
investors’ ability to bring claims in judicial forums that
they find favorable.

Response:

Please see the
revised disclosure to “Risk Factors” on page 13 and
Description of Securities on page 18. Although the company is
a smaller reporting
company, the Company intends to comply with Item 1A. Risk Factors
of Form 10-K and intends to include the aforementioned risk factor
in its future Annual Reports on Form 10-K.

Sincerely,

/s/ Stephen Epstein

Stephen
Epstein

Chief
Executive Officer

2

United States securities and exchange commission logo
July 2, 2020
Stephen Epstein
Chief Executive Officer
Healthcare Business Resources, Inc.
718 Thompson Lane, Suite 108-273
Nashville, Tennessee 37204
Re:Healthcare Business Resources, Inc.
Registration Statement on Form S-1
Filed June 8, 2020
File No. 333-239000
Dear Mr. Epstein:
            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.
Form S-1 Registration Statement Filed June 8, 2020
Prospectus Summary, page 2
1.We note your disclosure that states that "[d]istressed companies respond to challenges by
restructuring their business and capital structure, while healthy companies strive to
capitalize on opportunities by improving operations, reducing costs and maximizing
revenue." Please characterize this as your belief. In doing so, please elaborate upon the
statement that precedes it to explain why you believe that "many healthcare organizations
face significant operational and financial changes" and how your business model
addresses these changes.

 FirstName LastNameStephen Epstein
 Comapany NameHealthcare Business Resources, Inc.
 July 2, 2020 Page 2
 FirstName LastName
Stephen Epstein
Healthcare Business Resources, Inc.
July 2, 2020
Page 2
Selling Stockholders, page 13
2.Please revise the footnotes to match the data in the table. For example, footnotes 2, 11 and
13 appear to be missing or incorrect.
Security Ownership of Certain Beneficial Owners and Management, page 19
3.We note that your beneficial ownership table discloses the holdings of one officer and two
directors, but your beneficial ownership table lists "all executive officers and directors as a
group," as two people. Please correct this inconsistency. Also, please confirm the number
of shares owned by executive officers and directors as a group.
Description of Our Business, page 20
4.We note that your CEO provides the corporate office space to your company at no charge.
We also note your disclosure on page 26 that states that operating expenses were used to
pay rent. Please revise your disclosure to clarify this inconsistency.  Also, to the extent the
value of the rent that is being forgone by your CEO triggers applicable disclosure
requirements, please disclose this arrangement in your Certain Relationships and Related
Transactions section.
Management's Discussion and Analysis of Financial Condition, page 26
5.Please include disclosure in the Management's Discussion and Analysis section
to describe and quantify, to the extent possible, any known trends and uncertainties that
have had, or that you reasonably expect will have, a material impact on your business,
revenue or results of operations due to COVID-19. Refer to Item 303(a) of Regulation S-
K, Release No. 33-8350 and CF Disclosure Guidance: Topic No. 9.
Management's Discussion and Analysis of Financial Condition
Critical Accounting Policies
Revenue Recognition, page 27
6.We note your disclosure that you will be required to estimate the amount of royalties on
an accrual basis under ASU 2014-09.  Please tell us why this disclosure is applicable to
your proposed business.
Directors, Executive Officers, Promoters and Control Persons, page 28
7.Your web-site indicates that Mr. Epstein is your interim CEO and will perform such duties
until such time as the company retains a CEO and CFO.  Please revise to state as much
here and reconcile this disclosure with your disclosure elsewhere which states that your
"prospective management consulting and financial incentive program opportunities" will
be identified through your CEO's personal and professional relationships.

 FirstName LastNameStephen Epstein
 Comapany NameHealthcare Business Resources, Inc.
 July 2, 2020 Page 3
 FirstName LastName
Stephen Epstein
Healthcare Business Resources, Inc.
July 2, 2020
Page 3
Executive Compensation, page 29
8.We note that you have a verbal compensatory agreement with your CEO, President and
Chief Financial Officer. Please file a written description of the compensatory plan as an
exhibit. Refer to Item 601(b)(10)(iii)(A) of Regulation S-K.
Exhibit 23.1, page II-3
9.Please revise to file a dated consent of your Independent Registered Public Accounting
Firm. Refer to Item 601(b)(23)(i) of Regulation S-K.
General
10.We note that the forum selection provision in your bylaws identifies the Court of
Chancery of the State of Delaware (or, if the Court of Chancery does not have jurisdiction,
the federal district court for the District of Delaware) as the exclusive forum for certain
litigation, including any “derivative action.” Please revise your prospectus to provide
investors with disclosure about this provision, including whether this provision applies to
actions under the Securities Act or the Exchange Act. If so, please also state that there is
uncertainty as to whether a court would enforce such provision. If the provision applies to
Securities Act claims, please also state that investors cannot waive compliance with the
federal securities laws and the rules and regulations thereunder. In that regard, we note
that Section 22 of the Securities Act creates concurrent jurisdiction for federal and state
courts over all suits brought to enforce any duty or liability created by the Securities Act
or the rules and regulations thereunder. If this provision does not apply to actions arising
under the Securities Act or Exchange Act, please also ensure that the exclusive forum
provision in the governing documents states this clearly, or tell us how you will inform
investors in future filings that the provision does not apply to any actions arising under the
Securities Act or Exchange Act.

Additionally, if the forum selection provision applies to claims made under the federal
securities laws, please revise to include disclosure regarding the risks or other impacts of
the provision on investors, including but not limited to increased costs to bring a claim
and the potential discouraging of claims or limitation of investors’ ability to bring claims
in judicial forums that they find favorable.

            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.

 FirstName LastNameStephen Epstein
 Comapany NameHealthcare Business Resources, Inc.
 July 2, 2020 Page 4
 FirstName LastName
Stephen Epstein
Healthcare Business Resources, Inc.
July 2, 2020
Page 4
            You may contact Aamira Chaudhry at (202) 551-3389 or Bill Thompson at (202) 551-
3344 if you have questions regarding comments on the financial statements and related
matters.  Please contact Cara Wirth at (202) 551-7127 or Mara Ransom at (202) 551-3264 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Joel Arberman