ASI Aviation, Inc.
11921 Freedom Drive, Suite 550
Reston, VA 20190
July 23, 2019
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC. 20549
Attn: Jay Ingram, Legal Branch Chief
| Re: | ASI Aviation, Inc. | |
| Offering Statement on Form 1-A | ||
| Post-qualification Amendment No. 1 | ||
| Filed July 17, 2019 | ||
| File No. 024-10786 |
Dear Ms. McHale:
We understand that the staff of the U.S. Securities and Exchange Commission (the “Commission”) has completed its review of Post-qualification Amendment No. 1 to the Offering Statement on Form 1-A (the “Offering Statement”) of ASI Aviation, Inc. (the “Company”) and we hereby request that the Commission approve the qualification of the Offering Statement as of 5:00 PM Eastern Daylight Time on Thursday, July 25, 2019. We note that there are no participants in the Company’s offering that are required to clear compensation arrangements with FINRA.
We request that we be notified of such qualification by a telephone call to Mr. Paul Levites at (202) 869-0888 ext. 103, or in his absence Lou Bevilacqua, of Bevilacqua PLLC, at (202) 869-0888 ext. 100. We also respectfully request that a copy of the written order from the Commission verifying the date and time of qualification of the Company’s Offering Statement be sent to Bevilacqua PLLC, attention: Paul C. Levites, via email atpaul@bevilacquapllc.com.
| Sincerely, | |||
| ASI Aviation, Inc. | |||
| By: | /s/ Dr. Brajnandan B. Sahay | ||
| Dr. Brajnandan B. Sahay | |||
| Chief Executive Officer | |||
| cc: | Louis A. Bevilacqua, Esq. | ||
| dd: | Sergio Chinos, Staff Attorney | ||
