SecProbe.io

CORRESP
1
filename1.htm

April
28, 2026

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Washington,
D.C. 20549

    Re:
    Syntec
    Optics Holdings, Inc.

    Registration
    Statement on Form S-1 (Registration No. 333-295335)

    Concurrence
    in Acceleration Request

Ladies
and Gentlemen:

H.C.
Wainwright & Co., LLC (“Wainwright”), acting as underwriter for the above-referenced offering, hereby concurs in the
request by Syntec Optics Holdings, Inc. that the effective date of the above-referenced registration statement be accelerated to 5:15
P.M. Eastern Time on Tuesday, April 28, 2026, or as soon as practicable thereafter, pursuant to Rule 461 under the Securities Act. Wainwright
affirms that it is aware of its obligations under the Securities Act in connection with this offering.

    Very
    truly yours,

    H.C.
    WAINWRIGHT & CO., LLC

    By:
    /s/
    Edward Silvera

    Name:
    Edward
    Silvera

    Title:
    Co-Chief
    Executive Officer

 430
Park Avenue | New York, New York 10022 | 212.356.0500

Security
services provided by H.C. Wainwright & Co., LLC | Member: FINRA/SIPC

CORRESP
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filename1.htm

SYNTEC
OPTICS HOLDINGS, INC.

515
LEE ROAD

ROCHESTER,
NY 14606

April
27, 2026

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Industrial Applications and Services

100
F Street, N.E.

Washington,
D.C. 20549

Attention:
Margaret Sawicki

    Re:
    Syntec
    Optics Holdings, Inc.

    Registration
    Statement on Form S-1

    Filed
    April 27, 2026

    File
    No. 333-295335 (the “Registration Statement”)

    Acceleration
    Request

Ladies
and Gentlemen:

In
accordance with Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended, Syntec Optics Holdings, Inc. (the
“Registrant”) hereby respectfully requests that the U.S. Securities and Exchange Commission accelerate the effective date
of the above-referenced Registration Statement to Tuesday, April 28, 2026, at 5:15 p.m., Eastern Time, or as soon as thereafter
practicable.

The
cooperation of the staff in meeting the timetable described above is very much appreciated.

Please
contact Rick Werner or Alla Digilova of Haynes and Boone, LLP, counsel to the Registrant, at (212) 659-4974 or (212) 659-4993, respectively,
with any questions regarding this request.

    Very
    truly yours,

    SYNTEC
    OPTICS HOLDINGS, INC.

    /s/
    Al Kapoor

    Al
    Kapoor, Chief Executive Officer

    cc:
    Haynes
    and Boone, LLP

    Rick
    Werner, Esq.

    Alla
    Digilova, Esq.

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 20, 2026

Al Kapoor
Chief Executive Officer
Syntec Optics Holdings, Inc.
515 Lee Road
Rochester, NY 14606

 Re: Syntec Optics Holdings, Inc.
 Draft Registration Statement on Form S-1
 Submitted April 14, 2026
 CIK No. 0001866816
Dear Al Kapoor:

 This is to advise you that we do not intend to review your registration
statement.

 We request that you publicly file your registration statement and
non-public draft
submission on EDGAR at least two business days 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 Margaret Sawicki at 202-551-7153 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Industrial Applications and Services
cc: Christopher R. Rodi, Esq.
</TEXT>
</DOCUMENT>