SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<TEXT>
 May 12, 2025

Claude Zdanow
Reporting Person
Mt Olympus Ventures, Inc.
8605 Santa Monica Boulevard, PMB 36522
Los Angeles, CA 90069

 Re: Onar Holding Corporation
 Schedule 13D filed March 31, 2025 by Claude Zdanow et al.
 File No. 005-90750
Dear Claude Zdanow:

 We have conducted a limited review of the above-captioned filing and
have the
following comment.

 Please respond to this letter by amending the filing or by providing
the requested
information. If you do not believe our comment applies to your facts and
circumstances or
that an amendment is appropriate, please advise us why in a response letter.

 After reviewing any amendment to the filing and any information provided
in
response to this comment, we may have additional comments.

Schedule 13D filed March 31, 2025
General

1. We note that the event reported as requiring the filing of the Schedule
13D was June
 14, 2024. Rule 13d-1(a) of Regulation 13D-G requires the filing of a
Schedule 13D
 within five business days after the date beneficial ownership of more
than five percent
 of a class of equity securities specified in Rule 13d-1(i)(1) was
acquired. Based on the
 June 14, 2024 event date, the Schedule 13D submitted on March 31, 2025
was not
 timely filed. Please advise us why the Schedule 13D was not filed within
the required
 five business days after the date of the acquisition.
 May 12, 2025
Page 2

 We remind you that the filing persons are responsible for the accuracy
and adequacy
of their disclosures, notwithstanding any review, comments, action or absence
of action by
the staff.

 Please direct any questions to Blake Grady at 202-551-8573 or Nicholas
Panos at
202-551-3266.

 Sincerely,

 Division of
Corporation Finance
 Office of Mergers &
Acquisitions
</TEXT>
</DOCUMENT>

August 5, 2024
Claude Zdanow
President and Chief Executive Officer
Reliant Holdings, Inc.
8605 Santa Monica Boulevard
PMB 36522
Los Angeles, CA 90069
Re:Reliant Holdings, Inc.
Preliminary Proxy Statement on Schedule 14A
Filed July 8, 2024
File No. 000-56012
Dear Claude Zdanow:
            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 their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:William Robinson Eilers, Esq.

CORRESP
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reliant_corresp.htmRELIANT HOLDINGS, INC.

 August 1, 2024

 VIA EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 Office of Real Estate and Construction

 100 F. Street, N.E.

 Washington, D.C. 20549

 Re: Reliant Holdings, Inc.

 Preliminary Proxy Statement on Schedule 14A

 Filed July 8, 2024

 File No. 000-56012

 Ladies and Gentlemen:

 I am writing today on behalf of Reliant Holdings, Inc. (the “Company”), in response to your comment letter issued on July 16, 2024 regarding the Preliminary Proxy Statement on Schedule 14A filed by the Company on July 8, 2024.

 For your convenience, the Staff's comments have been repeated below in their entirety, with the Company's response to a particular comment set out immediately underneath it. The headings and numbered paragraphs in this letter correspond to the headings and numbered paragraphs in the comment letter from the Staff. When indicated, the responses described below are included in our amendment to the Preliminary Proxy Statement on Schedule 14A. Capitalized terms used but not defined in this letter are intended to have the meanings ascribed to such terms in Preliminary Proxy Statement on Schedule 14A.

 Preliminary Proxy Statement on Schedule 14A filed July 8, 2024

 General

 1. It appears that the proposed amendment to your articles of incorporation for an increase in authorized common stock relates to your merger with Onar, as reflected in your Form 8-K filed on June 18, 2024. Therefore, please revise your proxy statement to provide the information, including financial statements, required by Items 11, 13, and 14 of Schedule 14A. See Note A of Schedule 14A.

 We have removed the increase in authorized as the Board has determined that it is not necessary at this time to increase the authorized. In the event that the Board determines that is necessary or the holders of any preferred stock make demand upon the Company, we will file either a Schedule 14A Proxy Statement or a 14C Information Statement and provide such financial statements and information as so required by Items 11, 13, and 14 of Schedule 14A, as required.

 2. Please revise your filing throughout to reflect that you are filing a proxy statement rather than an information statement.

 We have adjusted the language throughout to reflect that this is a proxy statement rather than an information statement.

 If you have any questions or comments regarding these responses or require any additional information, please do not hesitate to contact us or our counsel, Smith Eilers, PLLC me at (561) 484-7172.

  Very truly yours,

  /s/ Claude Zdanow

  Claude Zdanow

  Chief Executive Office

  Reliant Holding, Inc.

 cc: Smith Eilers, PLLC

July 16, 2024
Claude Zdanow
President and Chief Executive Officer
Reliant Holdings, Inc.
12343 Hymeadow Drive, Suite 3-A
Austin, TX 78750
Re:Reliant Holdings, Inc.
Preliminary Proxy Statement on Schedule 14A
Filed July 8, 2024
File No. 000-56012
Dear Claude Zdanow:
            We have reviewed your filing and have the following comments.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Preliminary Proxy Statement on Schedule 14A filed July 8, 2024
General
1.It appears that the proposed amendment to your articles of incorporation for an increase in
authorized common stock relates to your merger with Onar, as reflected in your Form 8-K
filed on June 18, 2024. Therefore, please revise your proxy statement to provide the
information, including financial statements, required by Items 11, 13, and 14 of Schedule
14A. See Note A of Schedule 14A.
2.Please revise your filing throughout to reflect that you are filing a proxy statement rather
than an information statement.
            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.

July 16, 2024
Page 2

            Please contact Benjamin Holt at 202-551-6614 or Brigitte Lippmann at 202-551-3713
with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:William Robinson Eilers, Esq.

CORRESP
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Reliant
Holdings, Inc.

12343
Hymeadow Drive, Suite 3-A

Austin,
Texas 78750

August
14, 2017

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Attn:
Ms. Pamela Long

100
F. Street, N.E.

Washington,
D.C. 20549

Re:

Request
for Acceleration of Effectiveness of Registration Statement on Form S-1 (File No. 333-214274) of Reliant Holdings, Inc. (the “Registrant”)

Dear
Ms. Long:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, we hereby request that the effectiveness of the above-captioned Registration
Statement (the “Registration Statement”) be accelerated so that such Registration Statement will become effective
on Monday, August 14, 2017, at 5:00 p.m., Eastern Time, or as soon thereafter as practicable.

Please
direct any comments or questions to our counsel, John S. Gillies, of The Loev Law Firm, PC, at (832) 380-4730.

    Sincerely,

    /s/ Michael Chavez

    Michael
Chavez

    Chief
Executive Officer

CORRESP
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August 9, 2017

Mr. Jay Ingram

Legal Branch Chief

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. 5 to Registration Statement on Form S-1

    Filed July 25, 2017

    File No. 333-214274

Dear Mr. Ingram:

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 August 4, 2017, relating to the Company’s Registration Statement on Form S-1/A Amendment No. 5 (File No. 333-214274)
(the “Registration Statement”) filed with the Commission on July 25, 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. 6 to the Registration Statement on Form S-1 (“Amendment No. 6”)
via EDGAR.

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

Plan of Operations, page 2

1.

You state that
with your current cash on hand, expected revenues and based on your current average monthly expenses that you do not anticipate
the need for any additional funds for approximately the next 12 months. However, you also disclose that you anticipate requiring
$200,000 to fund your operations over the next twelve months and based on your disclosure it appears the source of some of the
funding is external. Given this, it appears that you will need additional funding for the next 12 months. Please amend your filing
to clarify. Additionally, we note that your “Plan of Operations” disclosure on page 39 appears to contradict your
liquidity needs under the same heading on page 2. Please revise to correct.

RESPONSE:

The disclosures in the amended registration
statement have been updated and clarified to address your comment.

Mr. Jay Ingram

August 9, 2017

Page 2 of 2

Summary Financial Data, page 5

2.

Please amend
your filing to present financial data for the audited 2 years ended December 31, 2016, and comparative 3 months ended March 31,
2017. Refer to Item 301(d) of Regulation S-K for guidance. Also, please refer to Instructions 1 and 2 to Item 301 regarding the
presentation and the items to be included in the table. While you may include additional items under Instruction 2 that you believe
useful, reproduction of the entirety of the balance sheets and statements of operations appears contrary to the purpose of summary
financial data.

RESPONSE:

The Company has updated the amended
Registration Statement to address your comment, to update the summary financial data presented therein, and to only include information
the Company believes is useful and not a reproduction of the entirety of such financial information.

    Yours very truly,

    /s/ John S. Gillies

    John S. Gillies

    Senior Associate

Mail Stop 4631
August 4 , 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. 5 to Registration Statement on Form S-1
Filed July 25 , 2017
  File No. 333 -214274

Dear Mr. Chavez :

We have reviewed your amended registration statement  and have the following
comment s.  Please respond to this letter by amending your registration statement and providing
the requested information .  If you do not believe our comment s apply  to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewin g any amendment to your registration statement and the information you
provide in response to these  comment s, we may have  additional comments.

Plan of Operations, page 2

1. You state that with your current cash on hand, expected revenues and based on your
current average monthly expenses that you do not anticipate the need for any additional
funds for approximately the next 12 months.   However, you also disclose that you
anticipate requiring $200,000 to fund your operations over the next twelve months and
based on your disclosure it appears the source of some of the funding is external.   Given
this, it appears that you will need additional funding for the next12 months.   Please
amend your filing to clarify.   Additionally, we note that your “Plan of Operatio ns”
disclosure on page 39 appears to contradict your liquidity needs under the same heading
on page 2.  Please revise to correct.

Michael Chavez
Reliant Holdings, Inc.
July 25 , 2017
Page 2

 Summary Financial Data, page 5

2. Please amend your filing to present financial data for the audited 2 years ended December
31, 2016, and comparative 3 months ended March 31, 2017.   Refer to Item 301(d) of
Regulation S -K for guidance.   Also, please refer to Instructions 1 and 2 to Item 301
regarding the presentation and the items to be included in the table.   While you may
include  additional items under Instruction 2 that you believe useful, reproduction of the
entirety of the balance sheets and statements of operations appears contrary to the
purpose of summary financial data.

You may contact  Tracey McKoy  (Staff Accountant) 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 202-551-3397 with any other questio ns.

Sincerely,

 /s/ Jay Ingram

 Jay Ingram
Legal Branch Chief
Office of Manufacturing and
Construction

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

CORRESP
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July 25, 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. 4 to Registration Statement on Form S-1

    Filed May 4, 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 May 18, 2017, relating to the Company’s Registration Statement on Form S-1/A Amendment No. 4 (File No. 333-214274)
(the “Registration Statement”) filed with the Commission on May 4, 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. 5 to the Registration Statement on Form S-1 (“Amendment No. 5”)
via EDGAR.

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

General

1.

Please
note the updating requirements of Rule 8-08 of Regulation S-X. Liquidity and Capital Resources, page 42

RESPONSE:

The Company has updated Amendment No. 5
with unaudited financial statements as of March 31, 2017, and has additionally updated Liquidity and Capital Resources pursuant
to the requirements of Rule 8-08 of Regulation S-X.

Ms. Pamela Long

July 25, 2017

Page 2 of 2

2.

We
note your receivable of $10k associated with the construction of the personal swimming pool of Michael Chavez, CEO. Please tell
us whether you have collected this receivable from Mr. Chavez. If not, please tell us how you concluded that current classification
was appropriate and the receivable was fully collectible.

RESPONSE:

The Company has updated Amendment No. 5
to address your comment.

3.

We
note you had working capital of $45,982 as of December 31, 2015 and $42,309 as of September 30, 2016. We further note that you
had a working capital deficit of $12,309 as of December 31, 2016. However, your disclosure regarding the reasons for the change
in working capital is identical to your prior disclosure when you reported working capital. Please advise.

RESPONSE:

The Company has updated Amendment No. 5
to address the reasons for the change in working capital.

4.

Given
your negative working capital and cash flows from operating activities as of December 31, 2016, please disclose cash requirements
for the next 12 months and the source of such funds. Refer to Section 501.13.a of the Financial Reporting Codification for guidance.

RESPONSE:

The Company has updated Amendment No. 5
to address your comment.

    Yours very truly,,

    /s/
    John S. Gillies

    John S. Gillies

    Senior Associate

Mail Stop 4631
May 18 , 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. 4 to Registration Statement on Form S-1
Filed May 4 , 2017
  File No. 333 -214274

Dear Mr. Chavez :

We have reviewed your amended registration statement  and have the following
comment s.  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 reviewi ng any amendment to your registration statement and the information you
provide in response to this comment , we may have  additional comments.

General

1. Please note the updating requirements of Rule 8 -08 of Regulation S -X.

Liquidity and Capital Resources , page 42

2. We note your receivable of $10k associated with the construction of the personal
swimming pool of Michael Chavez, CEO.   Please tell us whether you have collected this
receivable from Mr. Chavez.   If not, please tell us how you concluded that cur rent
classification was appropriate and the receivable was fully collectible.

3. We note you had working capital of $45,982 as of December 31, 2015 and $42,309 as of
September 30, 2016.  We further note that you had a working capital deficit of $12,309 as
of December 31, 2016.  However, your disclosure regarding the reasons for the change in
working capital is identical to your prior disclosure when you reported working capital.
Please advise.

Michael Chavez
Reliant Holdings, Inc.
May 18 , 2017
Page 2

4. Given your negative working capital and cash flows from opera ting activities as of
December 31, 2016, please disclose cash requirements for the next 12 months and the
source of such funds.   Refer to Section 501.13.a of the Financial Reporting Codification
for guidance.

You may contact  Tracey McKoy  (Staff Accountant) 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 S livka,  for

 Pamela Long
Assistant Director
Office of Manufacturing and
Construction

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

CORRESP
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Reliant
Holdings, Inc.

12343
Hymeadow Drive, Suite 3-A

Austin,
Texas 78750

February
14, 2017

VIA
EDGAR AND EMAIL

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Attn:
Craig Slivka

100
F. Street, N.E.

Washington,
D.C. 20549

Re:

Withdrawal of Request for Acceleration of Effectiveness of Registration Statement on Form S-1 (File No. 333-214274) of
Reliant Holdings, Inc. (the “Registrant”)

Dear
Mr. Slivka:

Reference
is made to our letter, filed as correspondence via EDGAR on February 13, 2017, in which we requested the acceleration of the effective
date of the above-referenced Registration Statement for Tuesday, February 14, 2017, at 3:00 p.m., Eastern Time, or as soon thereafter
as practicable, in accordance with Rule 461 under the Securities Act of 1933, as amended. We are no longer requesting that such
Registration Statement be declared effective at this time and we hereby formally withdraw our request for acceleration of the
effective date.

Please
direct any comments or questions to our counsel, John S. Gillies, of The Loev Law Firm, PC, at (713) 524-4110, Extension 2.

    Sincerely,

    /s/
    Michael Chavez

    Michael Chavez

    Chief Executive Officer

CORRESP
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Reliant
Holdings, Inc.

12343
Hymeadow Drive, Suite 3-A

Austin,
Texas 78750

February
13, 2017

VIA
EDGAR AND EMAIL

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Attn:
Craig Slivka

100
F. Street, N.E.

Washington,
D.C. 20549

Re: Request
                                         for Acceleration of Effectiveness of Registration Statement on Form S-1 (File No. 333-214274)
                                         of Reliant Holdings, Inc. (the “Registrant”)

Dear
Mr. Slivka:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, we hereby request that the effectiveness of the above-captioned Registration
Statement (the “Registration Statement”) be accelerated so that such Registration Statement will become effective
on Tuesday, February 14, 2017, at 3:00 p.m., Eastern Time, or as soon thereafter as practicable.

Please
direct any comments or questions to our counsel, John S. Gillies, of The Loev Law Firm, PC, at (713) 524-4110, Extension 2.

    Sincerely,

    /s/ Michael
    Chavez

    Michael Chavez

    Chief Executive Officer

CORRESP
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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

Mail Stop 4631
January 23, 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. 2 to Registration Statement on Form S-1
Filed January 13, 2017
  File No. 333 -214274

Dear Mr. Chavez :

We have reviewed your amended registration statement  and have the following comment .
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 reviewi ng any amendment to your registration statement and the information you
provide in response to this comment , we may have  additional comments.

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 res ults, particularly for trend purposes and discerning future
prospects.

Michael Chavez
Reliant Holdings, Inc.
January 23, 2017
Page 2

 You may contact  Tracey McKoy  (Staff Accountant) 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

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January 12, 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. 1 to Registration Statement on Form S-1

    Filed December 28, 2016

    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 11, 2017, relating to the Company’s Registration Statement on Form S-1/A Amendment No. 1 (File No. 333-214274)
(the “Registration Statement”) filed with the Commission on December 28, 2016, 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. 2 to the Registration Statement on Form S-1 (“Amendment No. 2”)
via EDGAR.

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

General

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.

Ms. Pamela Long

January 12, 2017

Page 2 of 3

 RESPONSE:

Amendment No. 2
has been updated with entire supplemental response to the Staff’s prior comment 1.

Risk Factors, page 9

Government regulations could increase
the cost of our construction . . ., 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.

 RESPONSE:

The Company has
combined the two risk factors into one risk factor in Amendment No. 2.

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 cost 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.

 RESPONSE:

The Company currently
builds the cost of permitting and compliance into its current pricing, it cannot however build in the cost of potential future
liability for environmental matters which are currently unknown and can’t be estimated. The Company has clarified in the
updated risk factor that while it currently passes the costs of permitting and compliance on to its customers, if such costs increase
in the future, customers may be unwilling to pay such costs, and it could result in a decrease in demand for the Company’s
services or margins. The Company has also added similar disclosure under “Government Regulations”.

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 year 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.

Ms. Pamela Long

January 12, 2017

Page 3 of 3

 RESPONSE:

The Company has
expanded upon and clarified the reasons for the changes in its results of operations in Amendment No. 2.

Exhibit 5.1

5.       We
note your counsel’s revised legal opinion refers specifically 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.

 RESPONSE:

The legal opinion
has been revised to relate to the registration statement and any potential amendments.

Yours
very truly,

/s/
John S. Gillies

John S. Gillies

Senior
Associate

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

CORRESP
1
filename1.htm

December
28, 2016

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.

Registration
Statement on Form S-1

Filed
October 27, 2016

File
No. 333-214274

Dear
Ms. Long:

On
behalf of Reliant Holdings, Inc., a Nevada corporation (the “Company”), we would like to thank you for your
prompt review of the Company’s Registration Statement on Form S-1 (File No. 333-214274) (the “Registration Statement”)
originally filed with the Securities and Exchange Commission (the “Commission”) on October 27, 2016, 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”). We
are responding to comments on the Registration Statement provided by the staff (the “Staff”) of the Commission
by letter dated November 22, 2016.

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

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

 General

 1. Please
                                         advise us of all registration statements of companies for which your sole Director and
                                         President may have acted as a promoter or in which he had a controlling interest. Describe
                                         in detail the nature and extent of the direct or indirect relationship between your sole
                                         Director and President and those companies and their affiliates. Indicate which companies
                                         are now viable or dormant and which businesses have been modified and restated from that
                                         described in their offering documents, noting the companies that are still actively reporting
                                         with the Commission.

Ms.
Pamela Long

December
28, 2016

Page
2 of 8

RESPONSE:

Mr.
Chavez was the President, Chief Executive Officer, Chief Financial Officer, Secretary, director and 54.2% owner of Allmarine Consultants
Corp. (File No. 333-130492)(“Allmarine”) from May 19, 2005 until August 29, 2007, the date that Allmarine completed
the acquisition of BAXL Technologies, Inc. (“BAXL”) in a merger (the “Merger”) pursuant
to an Agreement and Plan of Merger dated as of May 25, 2007 (the “Merger Agreement”), by and among Allmarine,
BAXL, and Allmarine Acquisition Corporation (“AAC”), Allmarine’s wholly-owned subsidiary.

Allmarine
planned to specialize in the administration of ship and corporate registries and provide maritime services to ship owners and
operators including registration and deletion of merchant vessels, bareboat/dual registry, registration of mortgages, classification
and technical surveys such as load line and Safety of Life at Sea (“SOLAS”). Allmarine also planned to conduct
pre-purchase, condition and cargo gear surveys, International Safety Management (“ISM”) consulting and certificates,
International Ship and Port Facility Security (“ISPS”) implementation and certificates and to offer Continuous
Discharge Certificates (“CDC”) for seafarers, vessel history and investigation, marine insurance, corporate
formation, and general consultancy to ship owners and managers. Allmarine had not however generated any revenues and had only
minimal assets as of the date of the Merger.

Pursuant
to BAXL’s filings with the Commission, BAXL manufactured and marketed products incorporating proprietary technology that
enabled the delivery of wired and wireless broadband applications including Internet access, Video on Demand, VoIP and Video Surveillance
over existing telephone wiring.

Pursuant
solely to a recent review of BAXL’s filings, it appears that BAXL ceased operations on July 14, 2008 and filed for Chapter
11 Bankruptcy protection and that BAXL has not filed any reports with the Commission since December 2008.

Mr.
Chavez had no control over BAXL or its filings subsequent to the Merger.

Other
than as described above, there are no other registration statements for companies which Mr. Chavez has acted as a promoter or
in which he had a controlling interest.

Amendment
No. 1 has been updated by the Company to include information regarding Mr. Chavez’s involvement with Allmarine even though
such transactions occurred over five years ago.

Ms. Pamela Long

December 28, 2016

Page 3 of 8

 2. We
                                         note that your counsel, David M. Loev, has been involved in the initial filings of several
                                         development stage and shell companies. Please provide us with an analysis regarding why
                                         Mr. Loev should not be considered a promoter as that term is defined under Rule 405 of
                                         Regulation C under the Securities Act.

RESPONSE:

Mr.
Loev has served as securities counsel to numerous companies over the past fifteen years, including several development stage companies
and companies which are considered ‘shell companies’ within the meaning of Rule 405 of the Securities Act of 1933,
as amended (the “Securities Act”), and Rule 12b-2 of the Securities Exchange Act of 1934, as amended, as well
as a significant number of companies which are not in the development stage.

Mr.
Loev is not a promoter of the Company however, as pursuant to Rule 405 of the Securities Act, a promoter is defined under Rule
405 of the Securities Act as:

 “(i)
      Any person who, acting alone or in conjunction with one or more other persons, directly or indirectly takes initiative in
founding and organizing the business or enterprise of an issuer; or

(ii)
       Any person who, in connection with the founding and organizing of the business or enterprise of an issuer, directly or indirectly
receives in consideration of services or property, or both services and property, 10 percent or more of any class of securities
of the issuer or 10 percent or more of the proceeds from the sale of any class of such securities.”

Neither
Mr. Loev, nor The Loev Law Firm, PC was involved with the founding or organizing of the business or enterprise of the Company
(The Loev Law Firm, PC was only engaged on May 25, 2016, solely to provide legal representation to the Company in connection with
the preparation and filing of the Registration Statement and did not previously consult with or discuss the Company with Mr. Chavez
or any other persons prior to that date) and has not directly or indirectly received in consideration of services or property,
or both services and property, 10 percent or more of any class of securities of the Company or 10 percent or more of the proceeds
from the sale of any class of such securities. Furthermore, neither Mr. Loev, nor The Loev Law Firm, PC, has received, or will
receive, any securities in the Company or any direct proceeds from the sale of Company stock as compensation for services rendered.

Mr.
Loev and The Loev Law Firm, PC, only serve as securities counsel to the Company and has no relationship with the Company outside
of such representation.

Accordingly,
neither Mr. Loev nor The Loev Law Firm, PC, meets the definition of “promoter” under Rule 405 of the Securities
Act.

Cover
Page

 3. Please
                                         remove Pink Sheets market from the list of market places.

RESPONSE:

The
reference to the Pink Sheets market has been removed from the list of market places in Amendment No. 1.

Prospectus
Summary, page 1

Description
of Business Operations, page 1

Ms. Pamela Long

December 28, 2016

Page 4 of 8

 4. We
                                         note your reference to awards won by Reliant Pools. Please revise your disclosure here
                                         and in your Business section to provide specifics regarding such awards.

RESPONSE:

The
Company has clarified in Amendment No. 1 that it won four Association of Pool & Spa Professionals (ARSP) Region 3 Design Awards
for its designs in 2016.

Plan
of Operations, page 2

 5. We
                                         note your disclosure that you do not anticipate the need for any additional funding in
                                         order to continue your operations at their current levels. Please reconcile this disclosure
                                         with your disclosure elsewhere in your registration statement that following this offering,
                                         as a public company, you will incur expenses of approximately $75,000 to comply with
                                         public company reporting requirements. We note that similar disclosure appears in the
                                         Summary of the Offering section and Business section of your registration statement.

RESPONSE:

The
Company has revised the disclosures in Amendment No. 1 to clarify that it does not currently anticipate the need for any additional
funding in the next 12 months to support its operations at current levels and pay the costs associated with being a public company,
but will require approximately $200,000 of funding in the next 12 months for expansion and acquisitions.

Risk
Factors, page 9

 6. Please
                                         revise this section in its entirety to remove redundant risk factors. By way of example,
                                         we note that (i) risks associated with compliance with Sarbanes-Oxley are located on
                                         both page 18 and page 19 and (ii) risks associated with the lack of a public market for
                                         your securities are included on page 20 and page 23.

 RESPONSE:

Amendment
No. 1 has been revised to remove redundant risk factors.

We
require additional financing, and we may not be able to raise funds . . ., page 9

Ms. Pamela Long

December 28, 2016

Page 5 of 8

 7. We
                                         note your disclosure that you need approximately $200,000 in additional funding to support
                                         your operations over the next 12 months. Please reconcile this disclosure with your disclosure
                                         elsewhere in your registration that you do not anticipate the need for any additional
                                         funding to continue your operations at their current levels.

RESPONSE:

Please
see the response to Comment 5 above.

Directors,
Executive Officers and Corporate Governance, page 26

 8. Please
                                         revise your biographical information for Elijah May to include a discussion of his principal
                                         occupations and employment during the past five years. See Item 11(k) of Form S-1 and
                                         Item 401(e)(1) of Regulation S-K.

RESPONSE:

The
Company has revised and expanded its disclosure of the biographical information for Elijah May as required by Item 11(k) of Form
S-1 and Item 401(e)(1) of Regulation S-K.

Executive
and Director Compensation, page 29

 9. Please
                                         revise the disclosure in your summary compensation table under Footnote (2) to provide
                                         more detail regarding the tax reimbursement.

RESPONSE:

The
Company has updated Amendment No. 1 to disclose that the tax reimbursement payments were made to reimburse the CEO and Controller
for personal income taxes that arose from when Reliant Pool’s entity type was that of a general partnership and each partner
(including the CEO and Controller) were taxed on their share of Reliant Pool’s profits. In May 2014, Reliant Pools converted
from a general partnership to a Nevada corporation. The tax reimbursement relates to the CEO’s and Controller’s share
of federal income tax on their pro rata share of Reliant Pool’s net income for federal income taxes prior to the date of
conversion from a general partnership to a corporation.

Description
of Business, page 32

Organizational
History, page 32

 10. Please
                                         revise your disclosure to describe the development of Reliant Pools, Inc. See Item 11(a)
                                         of Form S-1 and Item 101(h) of Regulation S-K.

RESPONSE:

The
Company has updated Amendment No. 1 to include a description of the development of Reliant Pools, Inc.

Competitive
Strengths, page 33

Ms. Pamela Long

December 28, 2016

Page 6 of 8

 11. We
                                         note your reference to a “pool development team.” We further note
                                         your references on page 34 to “schedulers” and “field supervisors.”
                                         Please reconcile with your disclosure on page 38 that you have four employees.

RESPONSE:

The
Company has clarified the description of pool development team to just refer to its employees and subcontractors. Additionally,
the Company has clarified that the “scheduler” and “field supervisor” is the same person.

Swimming
Pool Sales and Industry, page 33

 12. We
                                         note your disclosure on page 33 that you focus on the installation of concrete pools.
                                         We also note your disclosure on page 34 regarding vinyl-lined pools and fiberglass pools.
                                         Please tell us if you also design and install vinyl-lined and fiberglass pools.

RESPONSE:

The
Company has clarified that it does not design, build or install vinyl-lined or fiberglass pools.

Dependence
on a Limited Number of Customers, page 35

 13. Please
                                         tell us whether your large customers are the home builders you refer to on page 33.

RESPONSE:

The
Company has clarified in Amendment No. 1 that the large customers are not home builders and that other than through occasional
referrals from such entities, the Company does not have any agreements or relationships in place with home builders.

Government
Regulations, page 38

 14. Please
                                         expand your disclosure to discuss in more detail the regulations affecting and the effect
                                         of such regulations on your business. In particular, discuss the environmental laws your
                                         business is subject to as well as the broader financial impact that various regulations
                                         have on your business. See Item 11(a) of Form S-1 and Items 101(h)(4)(ix) and (xi) of
                                         Regulation S-K.

RESPONSE:

The
Company has updated Amendment No. 1 to expand the disclosure of the regulations affecting, and the effect of such
regulations, on its business, including environmental laws.

Management’s
Discussion and Analysis of Financial Condition . . ., page 4 0

Ms. Pamela Long

December 28, 2016

Page 7 of 8

 15. 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, you state that several results increased because of your referral business;

Mail Stop 4631
November 22, 2016

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

Re: Reliant Holdings, Inc.
Registration Statement on Form S-1
Filed October 27, 2016
  File No. 333 -214274

Dear Mr. Chavez :

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.

General

1. Please advise us of all registration statements of co mpanies for which your sole D irector
and President may have a cted as a promoter or in which he had a controlling interest.
Descri be in detail the nature and extent of the direct or indirect relationship between your
sole D irector  and President  and those companies and their affiliates.  Indicate which
companies are now viable or dormant and which businesses have been modified and
restated from that described in their offering documents, noting the companies that are
still actively reporting with the Commission.

Michael Chavez
Reliant Holdings, Inc.
November 22, 2016
Page 2

 2. We note that your counsel, David M. Loev, has been involved in the initial filings of
several development stage and shell co mpanies.  Please provide us with an analysis
regarding why Mr. Loev should not be considered a promoter as that term is defined
under Rule 405 of Regulation C under the Securities Act.

Cover Page

3. Please remove Pink Sheets market from the list of market p laces.

Prospectus Summary, page 1

Description of Business Operations, page 1

4. We note your reference to awards won by Reliant Pools.  Please revise your disclosure
here and in your Business section to provide specifics regarding such awards.

Plan of Operations, page 2

5. We note your disclosure that you do not anticipate the need for any additional funding in
order to continue your operations at their current levels.  Please reconcile this disclosure
with your disclosure elsewhere in your registration s tatement that following this offering,
as a public company, you will incur expenses of approximately $75,000 to comply with
public company reporting requirements.  We note that similar disclosure appears in the
Summary of the Offering section and Business section of your registration statement.

Risk Factors, page 9

6. Please revise this section in its entirety to remove redundant risk factors.  By way of
example, we note that (i) risks associated with compliance with Sarbanes -Oxley are
located on both page 1 8 and page 19 and (ii) risks associated with the lack of a public
market for your securities are included on page 20 and page 23.

We require additional financing, and we may not be able to raise funds . . ., page 9

7. We note your disclosure that you need  approximately $200,000 in additional funding to
support your operations over the next 12 months.  Please reconcile this disclosure with
your disclosure elsewhere in your registration that you do not anticipate the need for any
additional funding to contin ue your operations at their current levels.

Directors, Executive Officers and Corporate Governance, page 26

8. Please revise your biographical information for Elijah May to include a discussion of his
principal occupations and employment during the past fiv e years.  See Item 11(k) of
Form S -1 and Item 401(e)(1) of Regulation S -K.

Michael Chavez
Reliant Holdings, Inc.
November 22, 2016
Page 3

Executive and Director Compensation, page 29

9. Please revise the disclosure in your summary compensation table under Footnote (2) to
provide more detail regarding the tax reimbursement.

Description of Business, page 32

Organizational History, page 32

10. Please revise your disclosure to describe the development of Reliant Pools, Inc.  See Item
11(a) of Form S -1 and Item 101(h) of Regulation S -K.

Competitive Strengths, page 33

11. We note your reference to a “pool development team.”  We further note your references
on page 34 to “schedulers” and “field supervisors.”  Please reconcile with your disclosure
on page 38 that you have four employees.

Swimming Pool Sales and Industry,  page 33

12. We note your disclosure on page 33 that you focus on the installation of concrete pools.
We also note your disclosure on page 34 regarding vinyl -lined pools and fiberglass pools.
Please tell us if you also design and install vinyl -lined and fib erglass pools.

Dependence on a Limited Number of Customers, page 35

13. Please tell us whether your large customers are the home builders you refer to on page
33.

Government Regulations, page 38

14. Please expand your disclosure to discuss in more detail the r egulations affecting and the
effect of such regulations on your business.  In particular, discuss the environmental laws
your business is subject to as well as the broader financial impact that various regulations
have on your business.  See Item 11(a) of Form S -1 and Item s 101(h)(4)(ix) and (xi) of
Regulation S -K.

Michael Chavez
Reliant Holdings, Inc.
November 22, 2016
Page 4

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

15. 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, you state that several results increased because of your referral business; you
state that interest expense was due to an equipment purchase; and you state that operating
expenses increased due to the addition of personnel to help with increased operations.
See Item 11(h) of Form S -1 and Item 303 of Regulation S -K.

Results of Operations, page 41

16. Gross margin increased from 19% of revenue for the fiscal year ended December 31,
2014, to 27% for the same period in 2015.  Please amend your filing to provide a more
robust analysis of the contributing factors (i.e. lower cost of supplies, decre ased salaries,
increased selling price, etc.) driving the increase in gross margin.  Refer to Item 303 of
Regulation S -K for guidance.

Liquidity and Capital Resources, page 42

17. Please amend your filing to explain the nature of your $10,000 federal income tax
receivable as of June 30, 2016.  Refer to Item 303 of Regulation S -K for guidance.

Exhibits

18. We note that you have provided  a form  of legality  opinion .  Please file an executed
opinion  before you request acceleration of the effectiveness of your regis tration
statement.  See Section III.D.3 of Staff Legal Bulletin No. 19 (October 14, 2011).

19. Because the opinion that the common stock has been “validly issued” is understood to
mean that the registrant is validly existing under the laws of the jurisdiction  in which it is
incorporated, and the securities are duly authorized, please remove the assumption in
subparagraph (4) on page 2 of the legal  opinion that the Company will at all times remain
duly organized, validly existing, and in good standing under the laws of the State of
Nevada.  See Section II.B.1.a of Staff Legal Bulletin No. 19 (October 14, 2011).

We remind you that the company and its management a re 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.

Michael Chavez
Reliant Holdings, Inc.
November 22, 2016
Page 5

 You may contact  Tracey McKoy  (Staff Accountant) at 202-551-3772  or Terence O’Brien
(Accounting Branch Chief ) at 202-551-3355  if you have questions re garding comments on 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