Randolph Acquisitions, Inc.
4228 1st Ave, Unit 15,
Tucker, GA 30084
(404) 867-3110
Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549
| Re: | Randolph Acquisitions, Inc. |
| | Registration Statement on Form S-1 |
| | File No. 333-216730 |
Ladies and Gentlemen:
In regard to the above referenced Registration Statement, Randolph Acquisitions, Inc. (the “Company”) and its management acknowledge that:
| · | Should the Commission or its staff, acting pursuant to its delegated authority, declare the Registration Statement 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 Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and |
| · | The Company 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. |
Sincerely,
Randolph Acquisitions, Inc.
/s/ Richard Randolph
Chief Executive Officer