SecProbe.io

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 July 15, 2025

Guy Newman
Chief Financial Officer
Trutankless, Inc.
15900 North 78th Street, Suite 200
Scottsdale, AZ 85260

 Re: Trutankless, Inc.
 Form 10-K for the Year Ended December 31, 2023
 File No. 000-54219
Dear Guy Newman:

 We issued comments on the above captioned filing on June 2, 2025. On
June 24,
2025, we issued a follow-up letter informing you that comments remained
outstanding and
unresolved, and absent a substantive response, we would act consistent with our
obligations
under the federal securities laws.

 As you have not provided a substantive response, we are terminating our
review and
will take further steps as we deem appropriate. These steps include releasing
publicly,
through the agency's EDGAR system, all correspondence, including this letter,
relating to the
review of your filing, consistent with the staff's decision to publicly release
comment and
response letters relating to disclosure filings it has reviewed.

 Please contact Ernest Greene at 202-551-3733 or Anne McConnell at
202-551-3709
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
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<DOCUMENT>
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<TEXT>
 June 24, 2025

Guy Newman
Chief Financial Officer
Trutankless, Inc.
15900 North 78th Street, Suite 200
Scottsdale, AZ 85260

 Re: Trutankless, Inc.
 Form 10-K for the Year Ended December 31, 2023
 File No. 000-54219
Dear Guy Newman:

 We issued a comment to you on the above captioned filing on June 2,
2025. As of the
date of this letter, this comment remains outstanding and unresolved. We expect
you to
provide a complete, substantive response to this comment by July 8, 2025.

 If you do not respond, we will, consistent with our obligations under
the federal
securities laws, decide how we will seek to resolve material outstanding
comments and
complete our review of your filing and your disclosure. Among other things, we
may decide
to release publicly, through the agency's EDGAR system, all correspondence,
including this
letter, relating to the review of your filings, consistent with the staff's
decision to publicly
release comment and response letters relating to disclosure filings it has
reviewed.

 Please contact Ernest Greene at 202-551-3733 or Anne McConnell at
202-551-3709
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>

<DOCUMENT>
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<FILENAME>filename2.txt
<TEXT>
 June 2, 2025

Guy Newman
Chief Financial Officer
Trutankless, Inc.
15900 North 78th Street, Suite 200
Scottsdale, AZ 85260

 Re: Trutankless, Inc.
 Form 10-K for the Year Ended December 31, 2023
 File No. 000-54219
Dear Guy Newman:

 We have reviewed your May 20, 2025 filing in response to our comment
letter and
have the following comment.

 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.
Unless we note otherwise, any references to prior comments are to comments in
our October
9, 2024 letter.

Form 10-K for the Year Ended December 31, 2023
General

1. We note that you have not filed your Form 10-K for the year ended
December 31,
 2024 or any subsequent exchange act reports and these filings are
delinquent. Please
 file all delinquent exchange act reports.
 Please contact Ernest Greene at 202-551-3733 or Anne McConnell at
202-551-3709 if
you have questions regarding comments on the financial statements and related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>

CORRESP
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tkls_corresp.htmFebruary 5, 2025

 United States Securities and Exchange Commission

 Division of Corporation Finance

 Attn: Ernest Greene

 100 F Street, N.E.

 Washington, DC 20549

   Re:

   TruTankless, Inc.

 Form 10-K for the Year Ended December 31, 2023

 Filed June 26, 2024

 File No. 000-54219

 Mr. Greene:

 Trutankless, Inc. (the “Company”) is in receipt of the of the comment letter from staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission dated October 9, 2024 (the “Comment Letter”) and provides the following response to the comment contained in the Comment Letter relating to the above-referenced filing.

 In response to the following enumerated comment in the Comment Letter, we respectfully submit the following response:

 Form 10-K for the Year Ended December 31, 2023

 Report of Independent Registered Public Accounting Firm, page F-1

      1.

   We note you only include audited financial statements as of and for the year ended December 31, 2023. Please amend your Form 10-K to include audited financial statements as of and for the year ended December 31, 2022 and ensure that audit is performed by a firm that is currently registered with the Public Company Accounting Oversight Board (PCAOB). Since the PCAOB revoked the registration of Gries & Associates, LLC on March 5, 2024, you are required to have your prior year financial statements reaudited by a firm that is currently registered with the PCOAB. Refer to PCAOB Rule 2100 and Rules 2-02, 2-05 and 8-02 of Regulation S-X. In addition, based on the fact your Form 10-K was filed without required audited financial statements and the fact you concluded ICFR was not effective due to several material weaknesses you identified that have not been remediated, it is not clear how management concluded DCP was effective in the Form 10-K. Please advise or revise.

 Response:  Since receipt of the Comment Letter, the Company has been in contact with its current independent auditor, Victor Mokuolu, CPA PLLC (the “Auditor”) to reaudit the financial statements as of and for the year ended December 31, 2022 (the “2022 Financials”).  The Auditor is still working through the 2022 Financials, but has been delayed because the Comment Letter came during the busy time of the third quarter where the Auditor was working on other client matters and had difficulty in shuffling extra staff to reaudit the 2022 Financials.  There have also been additional delays due to the change in the Company’s management and the audit preparation team since the date the 2022 Financials were prepared so it has taken longer than anticipated to track down all supporting documentation, work papers and schedules.  The Auditor has advised that they have made significant progress on the reaudit of the 2022 Financials but have informed the Company that they still need several more weeks to complete their audit.  The Company and the auditor are tirelessly working to complete the reaudit of the 2022 Financials and plan to file an amended Form 10-K for the year ended December 31, 2023, which will include the audited financial statements of both the year ended December 31, 2022 and December 31, 2023, as soon as the reaudit of the 2022 Financials is complete.

  1

 The Company acknowledges that the Company and its management are responsible for the adequacy and accuracy of the disclosure in the filing, notwithstanding any review, comments, action or absence of action by the staff of the Commission.

 Sincerely,

 TruTankless, Inc.

    /s/ Guy Newman

 Guy Newman

 CEO

  2

January 22, 2025
Guy Newman
Chief Financial Officer
Trutankless, Inc.
15900 North 78th Street, Suite 200
Scottsdale, AZ 85260
Re:Trutankless, Inc.
Form 10-K for the Year Ended December 31, 2023
Filed June 26, 2024
File No. 000-54219
Dear Guy Newman:
            We issued a comment to you on the above captioned filing on October 9, 2024. As of
the date of this letter, this comment remains outstanding and unresolved. We expect you to
provide a complete, substantive response to this comment by February 5, 2025.
            If you do not respond, we will, consistent with our obligations under the federal
securities laws, decide how we will seek to resolve material outstanding comments and
complete our review of your filing and your disclosure. Among other things, we may decide
to release publicly, through the agency's EDGAR system, all correspondence, including this
letter, relating to the review of your filings, consistent with the staff's decision to publicly
release comment and response letters relating to disclosure filings it has reviewed.
            Please contact Ernest Greene at 202-551-3733 or Anne McConnell at 202-551-3709
with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
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tkls_corresp.htm

 VIA EDGAR ONLY

 October 22, 2024

 United States Securities and Exchange Commission

 Attn: Anne McConnell

 Division of Corporation Finance

 Office of Manufacturing

 100 F Street, N.E.

 Washington, D.C. 20549

   Re:

   Trutankless, Inc.

 Form 10-K for the Year Ended December 31, 2023

 Filed June 26, 2024

 File No. 000-54219

 Dear Ms. McConnell:

 Pursuant to your telephone conversation today with our securities counsel, Trutankless, Inc. (“Trutankless”) is in receipt of the comment letter dated October 9, 2024 from the staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission (the “Comment Letter”) and provides the following response to the comment contained in the Comment Letter relating to the above-referenced filing.

 In response to the following enumerated comment in the Comment Letter, we respectfully submit the following response:

 Form 10-K for the Year Ended December 31, 2023

 Report of Independent Registered Public Accounting Firm, page F-1

      1.

   We note you only include audited financial statements as of and for the year ended December 31, 2023. Please amend your Form 10-K to include audited financial statements as of and for the year ended December 31, 2022 and ensure that audit is performed by a firm that is currently registered with the Public Company Accounting Oversight Board (PCAOB). Since the PCAOB revoked the registration of Gries & Associates, LLC on March 5, 2024, you are required to have your prior year financial statements reaudited by a firm that is currently registered with the PCOAB. Refer to PCAOB Rule 2100 and Rules 2-02, 2-05 and 8-02 of Regulation S-X. In addition, based on the fact your Form 10-K was filed without required audited financial statements and the fact you concluded ICFR was not effective due to several material weaknesses you identified that have not been remediated, it is not clear how management concluded DCP was effective in the Form 10-K. Please advise or revise.

  Response: We have engaged our current auditor, Victor Mokuolu, CPA PLLC (“VMCPA”), who is currently registered with the PCAOB, to reaudit our financial statements for the year ended December 31, 2022.  We have been advised by VMCPA that the audit of the financial statements for the year ended December 31, 2022 will be completed in approximately six (6) weeks.  Once that audit is complete, we will file an amended Form 10-K to include those financial statements and will also update the Form 10-K to revise management’s conclusion regarding disclosure controls and procedures.

 Thank you for your assistance and review.

 Sincerely,

 Trutankless, Inc.

     /s/ Guy Newman

  Guy Newman

  Chief Executive Officer

October 9, 2024
Guy Newman
Chief Financial Officer
Trutankless, Inc.
15900 North 78th Street, Suite 200
Scottsdale, AZ 85260
Re:Trutankless, Inc.
Form 10-K for the Year Ended December 31, 2023
Filed June 26, 2024
File No. 000-54219
Dear Guy Newman:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
            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.
Form 10-K for the Year Ended December 31, 2023
Report of Independent Registered Public Accounting Firm, page F-1
1.We note you only include audited financial statements as of and for the year ended
December 31, 2023. Please amend your Form 10-K to include audited financial
statements as of and for the year ended December 31, 2022 and ensure that audit is
performed by a firm that is currently registered with the Public Company Accounting
Oversight Board (PCAOB). Since the PCAOB revoked the registration of Gries
& Associates, LLC on March 5, 2024, you are required to have your prior year
financial statements reaudited by a firm that is currently registered with the PCOAB.
Refer to PCAOB Rule 2100 and Rules 2-02, 2-05 and 8-02 of Regulation S-X. In
addition, based on the fact your Form 10-K was filed without required audited
financial statements and the fact you concluded ICFR was not effective due to several
material weaknesses you identified that have not been remediated, it is not clear how
management concluded DCP was effective in the Form 10-K. Please advise or revise.

October 9, 2024
Page 2
            In closing, 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 Ernest Greene at 202-551-3733 or Anne McConnell at 202-551-3709
with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
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Correspondence

 August 29, 2018

 United States Securities and Exchange Commission

 Attn: Greg Dundas

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, DC 20549

   Re:

   Trutankless, Inc.

   Registration Statement on Form S-1/A

   File No. 333-226543

 Ladies and Gentlemen:

 The undersigned registrant (the “Registrant”) hereby requests that the Securities and Exchange Commission (the “Commission”) take appropriate action to cause the above-referenced Registration Statement on Form S-1/A to become effective on August 30, 2018 at 4:30 p.m., Eastern Daylight Time, or as soon thereafter as is practicable.

 In connection with this request, the Registrant acknowledges that:

 ·

 should the Commission or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, 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, in declaring the filing effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

 ·

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

 Very truly yours,

 Trutankless, Inc.

 /s/ Robertson J. Orr

 Robertson J. Orr

 Chief Executive Officer and Director

November 14, 2016

Robertson J. Orr
Chief Executive Officer
Bollente Companies, Inc.
8800 N. Gainey Dr., Suite 270
Scottsdale, AZ 85258

Re: Bollente Companies, Inc.
Form 10 -K for Fiscal  Year Ended December 31, 2015
Filed May 9, 2016 , as amended
  File No. 000 -54219

Dear Mr. Orr :

We have completed our review of your filings .  We remind you that the company and its
management are responsible for the accuracy and adequacy of the ir disclosure s, notwithstanding
any review, comments, action or absence  of action  by the staff .

Sincerely,

 /s/ Kathleen Krebs, for

 Larry Spirgel
Assistant Director
AD Office 11 – Telecommunications

CORRESP
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    bolcltr.htm

Bollente Companies, Inc.

November 2, 2016

Larry Spirgel

Securities and Exchange Commission

100 F. Street, NE

Washington, D.C. 20549

Re:           Bollente Companies, Inc.

Form 10-K for Fiscal Year Ended December 31, 2015

Filed May 9, 2016

Form 10-Q for Fiscal Quarter Ended June 30, 2016

Filed August 22, 2016

File No. 000-54219

Dear Mr. Spirgel,

This correspondence is in response to your letter dated September 20, 2016 in reference to our above mentioned filings.

We have keyed our responses to your comment items in their original numeric order.

Form 10-K for Fiscal Year Ended December 31, 2015

Business, page 4

1. You disclose that you manufacture and distribute trutankless electric water heaters, online control panels, water circulation pumps and your new line of electric tankless water heaters geared toward budget-driven customers. It is not clear from your disclosure the extent to which each of these products is commercially available and is currently being manufactured and distributed. Please discuss the status of all your products and services.

Also discuss your manufacturing facilities, sources and availability of raw materials and the names of principal suppliers.

Response: We have revised our Business disclosure to clarify the status of our products and services  and also to discuss our manufacturing facilities, sources and availability of raw materials and the names of suppliers as follows:

Trutankless®

Our trutankless® water heaters are available through wholesale plumbing distributors, including Ferguson, Hajoca, Hughes Supply, WinSupply locations, Morrison Supply, and several regional distributors. A partial listing of wholesalers may be found on our website (www.trutankless.com).

Bollente Companies, Inc.

November 2, 2016

Page

MYTankless.com

MYTankless.com is available as a service to consumers of trutankless® water heaters. We have applications available for download from the Google Play and Apple iOS stores, which like the online control panels, allows monitoring and control of the tankless systems.

truCirc

Our new product, truCirc, was unveiled on January 20, 2015 at the 2015 International Builders’ Show in Las Vegas and is still in the development phase. While not yet commercially available, trutankless products are expected to be compatible. Alternatively, truCirc is expected to be a stand alone product for customers who don’t utilize trutankless.

Vero

Our trutankless® water heaters are available through wholesale plumbing distributors, including Ferguson, Hajoca, Hughes Supply, WinSupply locations, Morrison Supply, and several regional distributors. A partial listing of wholesalers may be found on our website (www.trutankless.com).

Customers and Markets

We sell our products to plumbing wholesale distributors and dealers.

Wholesalers. Approximately 98.3% of our sales in 2015 and 93.5% of our sales in 2014 were to wholesale distributors for commercial and residential applications. We rely on commissioned manufacturers’ representatives to market our product lines. Additionally, our products are sold to independent dealers throughout the United States.

Manufacturing and Distribution

Our principal supplier is Sinbon Electronics, a contract manufacturer and engineering company based in Taiwan with manufacturing facilities in China. Sinbon handles procurement and supply chain management. We have an engineering agreement which is ongoing and our manufacturing agreement is currently being negotiated.

Finished products are generally shipped Free on Board (FOB) Shanghai via ocean freight and are warehoused at Associated Global Systems located in Phoenix, Arizona. Merchandise is typically shipped using common carriers or freight companies are selected at the time of shipment based on order volume and the best available rates.

Bollente Companies, Inc.

November 2, 2016

Page

Management’s Discussion and Analysis of Financial Condition and Results of Operations

2. Quantify the contribution of each of your products and services to your revenues. Discuss any trends or uncertainties in the sales or costs of your products and services for the periods discussed.

Response: We have revised this section as follows:

Revenues

In the year ended December 31, 2015 we generated $265,504 in revenues, as compared to $238,912 in revenues in the prior year. The increase in sales was attributable mostly to sales of our trutankless® products and also the sale of Vero products which Vero products were not sold in 2014. Cost of goods sold was $342,999, as compared to $440,330 in the prior year.

To the knowledge of management, the Company is unaware of any trends or uncertainties in the sales or costs of our products and services for the periods discussed.

3. Please discuss the drivers behind any material changes in your research and development expenses. We note that your research and development expenses significantly decreased in the amount of $558,057 from the fiscal year ended December 31, 2014 to the fiscal year ended December 31, 2015.

Response: We revised this section to add:

In 2014, the Company was still spending funds on developing our products.

4. We note your references to loss on debt conversion. Please expand your discussion to clarify how the amount was determined.

Response: We revised our discussion as follows:

The loss on debt conversion amount was determined as follows: Amount owed to Perigon totaled $275,000. We issued 1,100,000 shares valued at $1.00 per share based on prior stock issuances. The total value converted was $1,100,000 which left an $825,000 loss on conversion.

5. Disclose the amount paid in royalties to unit holders for the periods being presented.

Response: We revised this section to disclose that zero (0) has been paid in royalties to unit holders for the periods presented.

Bollente Companies, Inc.

November 2, 2016

Page

Exhibits

6. Please file all exhibits required by Item 601 of Regulation S-K. We note that you did not file a number of exhibits including your articles of incorporation, bylaws, and a list of subsidiaries. We further note that you have not filed several material contracts, including the following:

·

Consulting and employment agreements;

·

The manufacturer incentive agreement with Meritage Homes Corporation;

·

Property leases, including with a related party;

·

Debt agreements, including with related parties; and

·

Unit purchase agreements entitling investors to royalty interests in the gross margin of product sold by Bollente International, Inc.

Response: We filed all exhibits required by Item 601 of Regulation S-K in the amended 10-K filing.

Form 10-Q for Fiscal Quarter Ended June 30, 2016

Management’s Discussion and Analysis of Financial Condition and Results of Operations

7. Please disclose the conversion terms of the secured convertible promissory notes and warrants outstanding as of June 30, 2016 and the convertible promissory note under the secured loan agreement executed on August 2, 2016.

Response: We disclosed the conversion terms of the secured convertible promissory notes and warrants outstanding as of June 30, 2016 and the convertible note under the secured loan agreement executed on August 2, 2016 as follows:

Secured Convertible Note and Warrant Financing

The outstanding principal amounts and accrued but unpaid interest of the notes are convertible at any time at the option of the holder into common stock at a conversion price of $1.00 per share.

Secured Loan Agreement and Warrant Agreement

The outstanding principal amount and accrued but unpaid interest of the Loan is convertible at any time at the option of the Lender into common stock at a conversion price of $0.25 per share.

Bollente Companies, Inc.

November 2, 2016

Page

Exhibits

8. Please file the secured convertible promissory notes and warrants financing agreement outstanding as of June 30, 2016 and the secured loan agreement and warrant agreement executed on August 2, 2016 as exhibits.

Response: We filed the secured convertible promissory notes and warrants financing agreement outstanding as of June 30, 2016 and the secured loan agreement and wattant agreement executed on August 2, 2016 as exhibits.

In connection with the response to your comments, Bollente Companies, Inc. acknowledges that:

·

the Company is responsible for the adequacy and accuracy of the disclosure in the filings;

·

staff Comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and

·

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

If you have any additional questions, please do not hesitate to contact me at (480) 275-7572.

/S/ Robertson J. Orr

Robertson J. Orr, President and CEO

Mail Stop 3720

October 17 , 2016

Robertson J. Orr
Chief Executive Officer
Bollente Companies, Inc.
8800 N. Gainey Dr., Suite 270
Scottsdale, AZ 85258

Re: Bollente Companies, Inc.
Form 10 -K for Fiscal Year Ended December 31, 2015
Filed May 9, 2016
Form 10 -Q for Fiscal Quarter Ended June 30, 2016
Filed August 22, 2016
File No. 000 -54219

Dear Mr. Orr :

 We issued comments to you on the above captioned filing on September 20 , 2016 .  As of
the date of this letter, these comments remain outstanding and unresolved.  We expect you to
provide a complete, substantive response to these comments by  October 3 1, 2016.

 If you do not respond, we will, consistent with our obligations under the  federal securities
laws, decide how we will seek to resolve material outstanding comments and complete our
review of your filing a nd your disclosure.  Among other things, we may decide to release
publicly, through the agency’s EDGAR system, all correspond ence, including this letter, relating
to the review of your filing, consistent with the staff’s decision to publicly release comment and
response letters relating to disclosure filings it has reviewed.

 Please contact Lahdan Rahmati, Law Clerk, at (202)  551-8199  or Carlos Pacho, Senior
Assistant Chief Accountant, at (202) 551 -3835 with any questions.

         Sincerely,

        /s/ Celeste M. Murphy for

        Larry Spirgel
        Assistant Director
        AD Office 11 – Telecommunications

Mail Stop 3720

September 20 , 2016

Robertson J. Orr
Chief Executive Officer
Bollente Companies, Inc.
8800 N. Gainey Dr., Suite 270
Scottsdale, AZ 85258

Re: Bollente Companies, Inc.
Form 10 -K for Fiscal  Year Ended December 31, 2015
Filed May 9, 2016
Form 10 -Q for Fiscal  Quarter Ended June 30, 2016
Filed August 22 , 2016
  File No. 000 -54219

Dear Mr. Orr :

We have reviewed your filing and have the following comments.  Please comply with
these comments in future filings.  Confirm in writing that you will do so.  In some of our
comments, we may ask you to provide us with information so we may better understand  your
disclosure.

Please respond to these comments 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 our
comments apply to your facts and circumstances, please te ll us why in your response.

After reviewing your response to these comments, we may have additional comments.

Form 10 -K for Fiscal Year Ended December 31, 2015

Business, page 4

1. You disclose that you manufacture and distribute trutankless electric wat er heaters,  online
control panels, water circulation pump s and your new line of electric tankless  water
heaters geared toward budget -driven customers.  It is not clear from your disclosure the
extent to which each of these products is commercially available and is currently being
manufactured and distributed.  Please discuss the status of all your  products and services.

Robertson J. Orr
Bollente Companies, Inc.
September 20 , 2016
Page 2

 Also discuss your manufacturing facilities, sources and availability of raw materials and
the names of principal suppliers.

Management’s Discussion and Analysis of Financial Condition and Results of Operations

2. Quantify the contribution of each of your products and services to your revenues.
Discuss any trends or uncertainties in the sales or costs of your products and services for
the periods discussed.

3. Please discuss the drivers behind any material changes in your resea rch and development
expenses .  We note tha t your research and development  expenses  significantly decreased
in the amount of $558,057 from the fiscal year ended December 31, 2014 to the fiscal
year ended December 31, 2015 .

4. We note your references to loss o n debt conversion.  Please expand your discussion to
clarify  how the amount was determined.

5.  Disclose the amount paid in royalties to unit holders for the periods being presented.

Exhibits

6. Please file all exhibits required by Item 601 of Regulation S -K.  We note that you did not
file a number of exhibits including your articles of incorporation, bylaws, and a list of
subsidiaries.  We further note that you have not filed several material contracts, including
the following:

 Consulting and employment ag reements ;
 The manufacturer incentive agreement with Meritage Homes Corporation ;
 Property leases, including with a related party ;
 Debt agreements, including with related parties ; and
 Unit purchase agreements entitling investors to royalty interests in the g ross margin
of product sold by Bollente International, Inc.

Form 10 -Q for Fiscal Quarter Ended June 30, 2016

Management’s Discussion and Analysis of Financial Condition a nd Results of Operations

7. Please disclose the conversion terms of the secured convertible promissory note s and
warrants  outstanding as of June 30, 2016 and the convertible promissory note under the
secured loan agreement  executed on August 2, 2016 .

Robertson J. Orr
Bollente Companies, Inc.
September 20 , 2016
Page 3

 Exhibits

8. Please file  the secured convertible promissory notes and warrant s financin g agreement
outstanding as of June 30, 2016  and the secured loan agreement and warrant agreement
executed on August 2, 2016  as exhibits .

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain th at the filing includes the information the Securities Exchange Act of
1934 and all applicab le Exchange Act rules require.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission  or any person under the federal securities laws of the United States.

You may contact Christie Wong, Senior Sta ff Accountant, at (202) 551 -3684  or Joseph
Cascarano, Senior Sta ff Accountant, at (202) 551 -3376  if you have questions regarding our
comment s on the financial statements and related matters.  Please contact Lahdan Rahmati, Law
Clerk, at (202) 551 -8199, or Kathleen Krebs, Special Counsel, at (202) 551 -3350, or me at (202)
551-3810 with any other questions.

Sincerely,

/s/ Larry Spirgel

Larry Spirgel
Assistant Director
AD Office 11 - Telecommunications

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4628

DIVISION OF
CORPORATION FINANCE MAIL STOP 4628
        December 15, 2009

Via U.S. Mail and Facsimile (702) 784-7601

Mr. Carlos Alcantara
Chief Executive Officer Alcantara Brands Corporation 3753 Howard Hughes Parkway Suite 200 Las Vegas, NV 89169
 Re: Alcantara Brands Corporation
  Item 4.01 Form 8-K/A
Filed September 18, 2009  Item 4.01 Form 8-K/A Filed October 27, 2009  Item 4.01 Form 8-K/A Filed December 9, 2009
  File No. 333-149804

 Dear Mr. Alcantara:   We have completed our review of your Form 8-K and related filings and have no further comments at this time.           S i n c e r e l y ,                                     C h r i s  W h i t e          B r a n c h  C h i e f   cc:  Donald J. Stoecklein, Esq., Stoecklein Law Group (619-704-1325)

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4628

DIVISION OF
CORPORATION FINANCE MAIL STOP 4628
        November 5, 2009

Via U.S. Mail and Facsimile (702) 784-7601
Mr. Carlos Alcantara
Chief Executive Officer Alcantara Brands Corporation 3753 Howard Hughes Parkway Suite 200 Las Vegas, NV 89169
 Re: Alcantara Brands Corporation
  Item 4.01 Form 8-K/A
Filed September 18, 2009  Item 4.01 Form 8-K/A Filed October 27, 2009
  File No. 333-149804

 Dear Mr. Alcantara:
We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your document in response to these comments.  If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.  After reviewing this information, we may raise additional comments.
Form 8-K/A No.3 filed October 27, 2009

1. We have reviewed your amended Form 8-K and correspondence filed October 27, 2009.  We reissue the comment 1 in our comment letter dated September 22, 2009.  Please revise your disclosure to explicitly state that Lawrence Scharfman Co. CPA PC resigned as your independent accountant on May 11, 2009 .  We
refer you to the guidance at Item 304(a)(1)(i) of Regulation S-K.

Mr. Carlos Alcantara
Alcantara Brands Corporation November 5, 2009 Page 2

Closing Comments

 As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provide us with a response.  You may wish to provide us with marked copies of the amendment to expedite our review.  Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information.  Detailed cover letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
 You may contact Suying Li at (202) 551-3335, if you have questions regarding
comments on the financial statements and related matters.  Please contact me at (202) 551-3461 with any other questions.          S i n c e r e l y ,             C h r i s  W h i t e          B r a n c h  C h i e f   cc:  Donald J. Stoecklein, Esq., Stoecklein Law Group (619-704-1325)

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4628

DIVISION OF
CORPORATION FINANCE MAIL STOP 4628
        September 22, 2009

Via U.S. Mail and Facsimile (702) 784-7601
Mr. Carlos Alcantara
Chief Executive Officer Alcantara Brands Corporation 3753 Howard Hughes Parkway Suite 200 Las Vegas, NV 89169
 Re: Alcantara Brands Corporation
  Item 4.01 Form 8-K/A
Filed September 18, 2009
  File No. 333-149804

 Dear Mr. Alcantara:
We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your document in response to these comments.  If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.  After reviewing this information, we may raise additional comments.       Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to working with you in these respects.  We welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Mr. Carlos Alcantara
Alcantara Brands Corporation
September 22, 2009 Page 2

1. Please revise your disclosure to explicitly state whether Lawrence Scharfman Co. CPA PC resigned , declined to stand of re-election or was dismissed on May 11,
2009.  We refer you to the guidance at Item 304(a)(1)(i) of Regulation S-K.
 2. Please amend your filing to state whether the Scharfman's report on your financial statements for the period from March 7, 2008 to December 31, 2008 contained an adverse opinion or a disclaimer of opinion or was qualified or modified as to uncertainty, audit scope, or accounting principles and also describe the nature of each such adverse opinion, disclaimer of  opinion, modification, or qualification.
We refer you to the guidance at Item 304(a)(1)(ii) of Regulation S-K.
 3. We note that you refer the reportable events to the definition at Item 304(a)(1)(iv) of Regulation S-K.  Please revise this reference to the Item 304(a)(1)(v) of Regulation S-K for the scope of the reportable events.
 Closing Comments

 As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provide us with a response.  You may wish to provide us with marked copies of the amendment to expedite our review.  Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information.  Detailed cover letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your amendment and responses to our comments.    We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment decision.  Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.     In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:  ‚ the company is responsible for the adequacy and accuracy of the disclosure in the filing;
‚ staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
‚ the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United

Mr. Carlos Alcantara
Alcantara Brands Corporation September 22, 2009 Page 3

States.

In addition, please be advised that the Division of Enforcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in our review
of your filing or in response to our comments on your filing.
You may contact Suying Li at (202) 551-3335, if you have questions regarding
comments on the financial statements and related matters.  Please contact me at (202) 551-3461 with any other questions.          S i n c e r e l y ,             C h r i s  W h i t e          B r a n c h  C h i e f

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

        September 15, 2009

Via U.S. Mail and Facsimile (702) 784-7601
Mr. Carlos Alcantara
Chief Executive Officer Alcantara Brands Corporation 3753 Howard Hughes Parkway Suite 200 Las Vegas, NV 89169
Re:  Alcantara Brands Corporation
  Item 4.01 Form 8-K
Filed August 13, 2009 Item 4.01 Form 8-K/A Filed September 15, 2009
  File No. 333-149804

Dear Mr. Alcantara:       We have completed our review of your Form 8-K and related filings and do not, at this time, have any further comments.             S i n c e r e l y ,                         /s/ Chris White                  C h r i s  W h i t e          B r a n c h  C h i e f

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C.   20549-4628

       DIVISION OF
CORPORATION FINANCE

   September 2, 2009
Via U.S. Mail and Facsimile (702) 784-7601

Mr. Carlos Alcantara
Chief Executive Officer Alcantara Brands Corporation 3753 Howard Hughes Parkway Suite 200 Las Vegas, NV 89169
Re:  Alcantara Brands Corporation
Form 10-K for the Fiscal Year Ended December 31, 2008
  Filed April 15, 2009   Item 4.01 Form 8-K
Filed August 13, 2009
  File No. 333-149804

Dear Mr. Alcantara:       Your most recent Form 10-K includes financial statements audited by Moore and Associates Chartered (“Moore”).  On A ugust 27, 2009, the Public Company Accounting
Oversight Board ("PCAOB") revoked the registra tion of Moore because of violations of
PCAOB rules and auditing standards in audi ting the financial statements, PCAOB rules
and quality controls standard s, and Section 10(b) of the Securities Exchange Act of 1934
and Rule 10b-5 thereunder, and noncooperation with a Board investigation.  You can find
a copy of the order at: http://www.pcaobus.org/Enforcement/Disci plinary_Proceedings /2009/08-27_Moore.pdf

  As Moore is no longer registered with  the PCAOB, you may not include Moore’s
audit reports or consents in  your filings with the Commi ssion made on or after August 27,
2009.  If Moore audited a year that you are re quired to include in your filings with the
Commission, then you should engage a firm that  is registered with the PCAOB to re-
audit that year.    Please amend your Item 4.01 Form 8-K, filed August 13, 2009, to  disclose that
the PCAOB revoked the regist ration of Moore on August 27, 2009 because of violations
of PCAOB rules and auditing standards in auditing the financial statements, PCAOB
rules and quality controls standards, and Sec tion 10(b) of the Securities Exchange Act of
1934 and Rule 10b-5 thereunder, and noncoope ration with a Board investigation.

Mr. Carlos Alcantara
Alcantara Brands Corporation September 2, 2009 Page 2
If you are unable to obtain an Exhibit 16 letter from Moore at the time you file
your Form 8-K – or an amended Exhibit 16 letter for an amended Form 8-K – please
disclose this fact in the Form 8-K.

Once you explain Moore’s registration revoc ation in an Item 4.01 Form 8-K, you
do not need to repeat this disclo sure in your next Form 10-K.
  Any amendment to Form 8-K should be file d within four business days of receipt
of this letter.  Please advise us as to ho w you intend to address any re-audit requirements
no later than September 11, 2009.  If you have  any questions, I can be reached at 202-
551-3461.
Sincerely,
          / s /  C h r i s  W h i t e           C h r i s  W h i t e
        B r a n c h  C h i e f

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C.   20549

       DIVISION OF
CORPORATION FINANCE

  August 18, 2009

Via U.S. Mail and Facsimile to 702-784-7601
Mr. Carlos Alcantara Chief Executive Officer Alcantara Brands Corporation 3753 Howard Hughes Parkway, Suite 200 Las Vegas, Nevada 89169  Dear Mr. Alcantara:           Your Form 10-K for the year ende d December 31, 2008 includes financial
statements audited by Lawrence Scharfman CPA PA (“Scharfman”).  On August 11,
2009, the Public Company Accounting Oversight Board ("PCAOB") revoked the registration of Scharfman because of deficienci es in the conduct of certain of its audits
and its procedures. You can find a copy of the order at http://www.pcaobus.org/Enforcement/D isciplinary_Proce edings/2009/08-
11_Scharfman.pdf .
  As Scharfman is no longer registered with the PCAOB, you may not include its
audit reports or consents in your future filings with the Commission.  If Scharfman
audited a year that you are required to incl ude in any filings made with the Commission
after August 11, 2009, you should have a firm that is registered with the PCAOB re-audit that year.    In providing the information that Item  304 of Regulation S-K requires, please
disclose in your 2009 Form 10-K that the PCAOB revoked the registration of Scharfman on August 11, 2009.  While this s ituation is not specifically described in the Item 304
disclosure requirements, we believe it is mate rial information that should be disclosed.
Please confirm in writing that the company w ill provide this disclosure in its 2009 Form
10-K.   If you have any questions, I can be reached at 202-551-3461.
Sincerely,
         C h r i s  W h i t e         B r a n c h  C h i e f

CORRESP
1
filename1.htm

ALCANTARA
BRANDS
CORPORATION

1101 E. TROPICANA AVE., SUITE 2118, LAS VEGAS, NV 89119

April 17, 2008

Carmen Moncada-Terry

Division of Corporate Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549-0405

			RE:

			Alcantara Brands Corporation

			Registration Statement on Form S-1 (Filed on 4/7/08)

			File No. 333-149804

Dear Ms. Moncada-Terry:

Alcantara Brands Corporation, hereby requests acceleration of effectiveness of the above referenced S-1 Registration Statement in accordance with Rule 461 under the Securities Act of 1933.  We are requesting effectiveness as of 10:00 A.M. EST on Monday, April 21, 2008.

In conjunction with this request for acceleration of the effective date of the above referenced registration statement, we acknowledge that:

			•

			should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, 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, in declaring the filing effective, does not relieve us from our full responsibility for the adequacy and accuracy of the disclosure in the filing; and

			•

			we may not assert the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

If you have any questions or need any information to grant effectiveness, please advise.

Please notify us upon effectiveness of the Registration at the fax number (949) 258-5112.

Thank you for your assistance.

Sincerely,

			/s/Carlos T. Alcantara

Carlos T. Alcantara, President

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE
Mail Stop 7010

April 2, 2008

Mr. Carlos T. Alcantara, President Alcantara Brands Corporation 1101 E. Tropicana Ave., Suite 2118 Las Vegas, NV 89119
Re: Alcantara Brands Corporation
  Registration Statement on Form S-1
Filed March 19, 2008
  File No. 333-149804

Dear Mr. Alcantara:

We have limited our review of your filing to those issues we have addressed in
our comments.  Where indicated, we think you should revise your document in response
to these comments.  If you disagree, we w ill consider your explanation as to why our
comment is inapplicable or a revision is unneces sary.  Please be as detailed as necessary
in your explanation.  In some of our comme nts, we may ask you to provide us with
information so we may better understand your  disclosure.  After reviewing this
information, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Form S-1 filed March 19, 2008

Cover Page

1. We note your discussion in the Risk F actor section where you disclose that
proceeds of the offering will be placed in  the general corporate account rather
than in an escrow account and therefore that the funds may be attached by your
creditors.  This fact should be promin ently disclosed on the cover page.  Please
expand your disclosure on the cover page  to clarify that although you intend to
“promptly return to the purchasers” all money paid for the shares without any
deductions, all the money may not be re turned because it may be subject to

Mr. Carlos T. Alcantara
Alcantara Brands Corporation
April 2, 2008 Page 2

creditor claims, including the claims of the law firm that assisted you with the
preparation of the filing and issued the legality opinion.

Exhibit 5

2. The opinion of counsel incorrectly refers  to a Form SB-1.  Please obtain a new
opinion of counsel referri ng to the correct form.
 Closing Comments

As appropriate, please amend your regist ration statement in response to these
comments.  You may wish to provide us with marked copies of the amendment to expedite our review.  Please furnish a cove r letter with your amendment that keys your
responses to our comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your amendmen t and responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Act of 1933 and that they have  provided all information investors require
for an informed investment decision.  Since the company and its management are in possession of all facts relating to a company’ s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.
Notwithstanding our comments, in the even t the company requests acceleration of
the effective date of the pending registration statement, it should furnish a letter, at the time of such request, acknowledging that:   ‚ should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose th e Commission from taking any action with
respect to the filing;
 ‚ the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective,  does not relieve the company from its full responsibility
for the adequacy and accuracy of the disclosure in the filing; and
 ‚ the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
  In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in connection
with our review of your filing or in response to our comments on your filing.

Mr. Carlos T. Alcantara
Alcantara Brands Corporation
April 2, 2008
Page 3

We will consider a written request for acceleration of the effective date of the
registration statement as conf irmation of the fact that t hose requesting acceleration are
aware of their respective re sponsibilities under the S ecurities Act of 1933 and the
Securities Exchange Act of 1934 as they rela te to the proposed public offering of the
securities specified in the above registration statement.  We will act  on the request and,
pursuant to delegated authority, grant acce leration of the effective date.
We direct your attention to Rules 46 0 and 461 regarding requesting acceleration
of a registration statement.  Please allow ad equate time after the filing of any amendment
for further review before submitting a request for acceleration.  Please provide this
request at least two business days in a dvance of the requested effective date.

 Please contact Carmen Moncada-Terry  at (202) 551-3687 or  me at (202) 551-
3611 with any questions.
Sincerely,

Anne Nguyen Parker Branch Chief
  cc: A. N. Parker
C. Moncada-Terry