SecProbe.io

CORRESP
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 SETO HOLDINGS, INC.

 6231 Columbia Park Road

 Hyattsville, Maryland 20785

 December 18, 2025

 VIA EDGAR

 Jan Woo

 Office of Technology

 Division of Corporation Finance

 Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:

 SETO Holdings, Inc.
 Post-Qualification Amendment No. 1 to

 Offering Statement on Form 1-A
 Filed December 16, 2025

 File No. 024-12665

 Dear Ms. Woo:

 On behalf of the Company, I respectfully request
that the qualification date of Post-Qualification Amendment No. 1 to the Offering Statement on Form 1-A (the "Offering Statement")
be accelerated and that the Offering Statement be declared qualified Friday, December 19, 2025, at 4:00 p.m. EDT, or as soon thereafter
as is reasonably practicable.

 In making this request, the Company represents
that the Offering Statement will be approved in the State of Colorado, upon qualification by the Securities and Exchange Commission (the
"Commission"), and acknowledges the following:

 - should the Commission or the Staff, acting pursuant to delegated
authority, declare the filing qualified, it does not foreclose the Commission from taking any action with respect to the filing;

 - the action of the Commission or the staff, acting pursuant to
delegated authority, to declare the filing qualified does not relieve the Company from its full responsibility for the adequacy and accuracy
of disclosure in the filing; and

 - the Company may not assert staff comments and/or qualification
as a defense in any proceeding initiated by the Commission or any person under the federal securities law of the United States.

 Very truly yours,

 /s/ Janon Costley

 Janon Costley

 Chief Executive Officer

 SETO Holdings, Inc.

CORRESP
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 SETO HOLDINGS, INC.

 6231 Columbia Park Road

 Hyattsville, Maryland 20785

 December 5, 2025

 VIA EDGAR

 Mariam Mansaray

 Office of Technology

 Division of Corporation Finance

 Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:
 SETO Holdings, Inc.

 Offering Statement on Form 1-A

 File No. 024-12665

 Dear Ms. Mansaray:

 On behalf of the Company, I respectfully request
that the qualification date of the Offering Statement be accelerated and that the Offering Statement be declared qualified Monday, December
8, 2025, at 3:00 p.m. EDT, or as soon thereafter as is reasonably practicable.

 In making this request, the Company represents
that the Offering Statement will be approved in the State of Colorado, upon qualification by the Securities and Exchange Commission (the
"Commission"), and acknowledges the following:

 ·
 should the Commission
or the Staff, acting pursuant to delegated authority, declare the filing qualified, it does not foreclose the Commission from taking any
action with respect to the filing;

 ·
 the action of the Commission
or the staff, acting pursuant to delegated authority, to declare the filing qualified does not relieve the Company from its full responsibility
for the adequacy and accuracy of disclosure in the filing; and

 ·
 the Company may not
assert staff comments and/or qualification as a defense in any proceeding initiated by the Commission or any person under the federal
securities law of the United States.

 Very truly yours,

 /s/ Janon Costley

 Janon Costley

 Chief Executive Officer

 SETO Holdings, Inc.

CORRESP
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 NEWLAN
LAW FIRM, PLLC

 2201 Long Prairie Road, Suite 107-762

 Flower Mound, Texas 75022

 December 1, 2025

 Mariam Mansaray

 Office of Technology

 Division of Corporation Finance

 Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:
 SETO Holdings, Inc.

 Offering Statement
on Form 1-A

 Filed September
10, 2025

 File No. 024-12665

 Dear Ms. Mansaray:

 With respect to the accompanying
Pre-Qualification Amendment No. 2 to the Offering Statement on Form 1-A of SETO Holdings, Inc. (the "Company"), please be
advised that Pre-Qualification Amendment No. 2 includes the following items that were included in Pre-Qualification Amendment No. 1:

 • The involvement of the named placement agent broker-dealer in the original filing has been cancelled.
Accordingly, the disclosure has been updated to reflect this change. Further, Exhibit 1.1 includes an amendment to the Placement Agent
and Advisory Services Agreement that specifically excludes the Company's obligation to compensate the broker-dealer with respect
to any Regulation A offering, including this offering.

 • Three selling shareholders that own a total of 1,000,000 shares of common stock have been added to the
offering.

 • The disclosure under Dilution, Use of Proceeds, Plan of Distribution, Selling Shareholders and Security
Ownership of Certain Beneficial Owners and Management reflects the changes indicated above.

 In addition, Pre-Qualification Amendment No. 2
includes the following additions, which occurred during the recent Federal government shutdown:

 • The Company acquired CapCity Beverage, LLC, the relevant agreement being filed as Exhibit 7.2 (see also
Exhibits 2.5 and 3.5). The financial statements of CapCity, LLC are included following the Pro Forma Financial Statement presentation.

 • The Company's Designation of Series C Preferred Stock is filed as Exhibit 2.5.

 • The Company's October 23, 2025, Securities Purchase Agreement and accompanying $25,000 principal
amount Convertible Promissory Note are filed as Exhibits 6.4 and 3.4, respectively.

 • The disclosure describes the establishment of an Advisory Board, the backgrounds of its initial members
and their financial arrangements. The agreements between the Company and the three advisory board members are filed as Exhibits 6.5, 6.6
and 6.7, respectively.

 _________________________________

 We believe that this filing
is now in order for qualification.

 Please feel free to contact
the undersigned at (940) 367-6154, should you have any questions regarding this letter or the Amendment.

 Thank you for your attention
in this matter.

 Sincerely,

 NEWLAN LAW FIRM, PLLC

 By: /s/ Eric Newlan

 Eric Newlan

 Managing Member

 cc: SETO Holdings, Inc.

CORRESP
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NEWLAN
LAW FIRM, PLLC

2201 Long Prairie Road, Suite 107-762

Flower Mound, Texas 75022

October 1, 2025

Mariam Mansaray

Office of Technology

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: SETO Holdings, Inc.

    Offering Statement
on Form 1-A

    Filed September
10, 2025

    File No. 024-12665

Dear Ms. Mansaray:

With respect to the accompanying
Pre-Qualification Amendment No. 1 to the Offering Statement on Form 1-A of SETO Holdings, Inc. (the “Company”), please be
advised of the following:

 • The involvement of the named placement agent broker-dealer in the original filing has been cancelled.
Accordingly, the disclosure has been updated to reflect this change. Further, Exhibit 1.1 includes an amendment to the Placement Agent
and Advisory Services Agreement that specifically excludes the Company’s obligation to compensate the broker-dealer with respect
to any Regulation A offering, including this offering.

 • Three selling shareholders that own a total of 1,000,000 shares of common stock have been added to the
offering.

 • The disclosure under Dilution, Use of Proceeds, Plan of Distribution, Selling Shareholders and Security
Ownership of Certain Beneficial Owners and Management reflects the changes indicated above.

_________________________________

We believe that this filing
is now in order for qualification.

Please feel free to contact
the undersigned at (940) 367-6154, should you have any questions regarding this letter or the Amendment.

Thank you for your attention
in this matter.

Sincerely,

NEWLAN LAW FIRM, PLLC

By: /s/ Eric Newlan

Eric Newlan

Managing Member

cc: SETO Holdings, Inc.

CORRESP
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SETO HOLDINGS, INC.

6231 Columbia Park Road

Hyattsville, Maryland 20785

September 30, 2025

VIA EDGAR

Mariam Mansaray

Office of Technology

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

  Re:
  SETO Holdings, Inc.

  Offering Statement on Form 1-A

  Filed September 10, 2025

  File No. 024-12665

Dear Ms. Mansaray:

On behalf of the SETO Holdings, Inc., I respectfully
withdraw the September 26, 2025, request for acceleration of the qualification date of the captioned Offering Statement on Form 1-A.

Very truly yours,

/s/ Janon Costley

Janon Costley

Chief Executive Officer

SETO Holdings, Inc.

CORRESP
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SETO HOLDINGS, INC.

6231 Columbia Park Road

Hyattsville, Maryland 20785

September 26, 2025

VIA EDGAR

Mariam Mansaray

Office of Technology

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: SETO Holdings, Inc.

    Offering Statement on Form 1-A

    Filed September 10, 2025

    File No. 024-12665

Dear Ms. Mansaray:

On behalf of the Company, I respectfully request
that the qualification date of the Offering Statement be accelerated and that the Offering Statement be declared qualified Tuesday, September
30, 2025, at 2:00 p.m. EDT, or as soon thereafter as is reasonably practicable.

In making this request, the Company represents
that the Offering Statement will be approved in the State of Colorado, upon qualification by the Securities and Exchange Commission (the
“Commission”), and acknowledges the following:

    ·
    should the
Commission or the Staff, acting pursuant to delegated authority, declare the filing qualified, it does not foreclose the Commission from
taking any action with respect to the filing;

    ·
    the action
of the Commission or the staff, acting pursuant to delegated authority, to declare the filing qualified does not relieve the Company from
its full responsibility for the adequacy and accuracy of disclosure in the filing; and

    ·
    the Company
may not assert staff comments and/or qualification as a defense in any proceeding initiated by the Commission or any person under the
federal securities law of the United States.

Very truly yours,

/s/ Janon Costley

Janon Costley

Chief Executive Officer

SETO Holdings, Inc.

September 17, 2025
Janon Costley
Chief Executive Officer
SETO Holdings, Inc.
6231 Columbia Park Road
Hyattsville, MD 20785
Re:SETO Holdings, Inc.
Offering Statement on Form 1-A
Filed September 10, 2025
File No. 024-12665
Dear Janon Costley:
            This is to advise you that we do not intend to review your offering statement.
            We will consider qualifying your offering statement at your request. In connection
with your request, please confirm in writing that at least one state has advised you that it is
prepared to qualify or register your offering. If a participant in your offering is required to
clear its compensation arrangements with FINRA, please have FINRA advise us that it has no
objections to the compensation arrangements prior to qualification.
            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 Mariam Mansaray at 202-551-6356 or Jan Woo at 202-551-3453 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Eric Newlan