Growth Stalk Holdings Corporation
11991 North Highway 99
Seminole, Oklahoma 74868
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
October 3, 2024
Re: Amended Withdrawal of Post-Effective Regulation A Offering
File No. 024-11847
Issuer: Growth Stalk Holdings Corporation (the “Company”)
Dear Sir or Madam:
Pursuant to Rule 259 under Regulation A of the Securities Act of 1933, as amended, and on behalf of the Company, we hereby request the withdrawal of: (a) the Post Qualification Offering Statement on Form 1-A (Amendment Number 1) filed on December 29, 2023; and (b) the Post Qualification Offering Statement on Form 1-A (Amendment Number 2) filed on June 12, 2024 (collectively, the “Offerings”). No Regulation A shares were sold in the Offerings and no funds were received by the Company regarding the Offerings. The Company’s reasons for requesting withdrawal of the Offerings are that: (a) the regulatory and auditing costs associated with the Offerings became cost prohibitive and became a material drain on the Company’s financial resources; and (b) the Offerings were a significant drain on the Company’s time resources, time that will in the future be better spent on the Company’s core business.
Please contact our Securities Counsel, Frederick M. Lehrer of the Law Firm of Frederick M. Lehrer at (561) 706-7646 or flehrer@securitiesattorney1.com if you have any questions.
Sincerely,
/s/ Joseph Babiak
Joseph Babiak
Chief Executive Officer