GenTech Holdings, Inc.
September 14, 2020
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
| RE: | GenTech Holdings, Inc. |
Offering Statement on Form 1-A
Post Qualification Amendment
Filed September 8, 2020
File No. 024-11055
Ladies and Gentlemen:
Gentech Holdings, Inc. (the “Company”), is filing with the Securities and Exchange Commission (the “Commission”), Post Qualification Amendment No. 5 to the Offering Statement on Form 1-A (“Amendment No. 5”) relating to the issuance by the Company of up to 129,400,000 of shares of Common Stock.
This letter also sets forth the Company’s responses to comments from the staff (the “Staff”) of the Division of Corporation Finance of the Commission provided telephonically regarding your review of the Offering Statement on Form 1-A, which was filed with the Commission on September 8, 2020.
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 Amendment No. 6. Capitalized terms used but not defined in this letter are intended to have the meanings ascribed to such terms in Amendment No. 6.
Per your oral comments, we have adjusted throughout the disclosure statement, including footnotes to the pro forma financials to clearly identify the source of funds used in the transaction with Sinister Labs, LLC.
If you have any questions or comments regarding these responses or require any additional information, please do not hesitate to contact me or our counsel, Eilers Law Group, P.A. at (786) 273-9152.
| Very truly yours, | |
| /s/ David Lovatt | |
| David Lovatt, CEO | |
| GenTech Holdings, Inc. |
| cc: | William Eilers, Esq. |
