April 5, 2019

Nirajkumar Patel
Chief Executive Officer
Quick Start Holdings, Inc.
401 N. Wickham Road, Suite 130
Melbourne, FL 32935

       Re: Quick Start Holdings, Inc.
           Amendment No. 2 to Registration Statement on Form 10-12G
           Filed March 25, 2019
           File No. 000-56016

Dear Mr. Patel:

       We have reviewed your amended filing and have the following comments. 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 tell us why in your
response.

     After reviewing your response and any amendment you may file in response
to these
comments, we may have additional comments. Unless we note otherwise, our
references to prior
comments are to comments in our March 1, 2019 letter.

Amendment No. 2 to Form 10

Prior and Current Shell Company Experience of Former Management and Former
Majority
Stockholder, page 10

1.    We reissue prior comment 2. Your response explains why you believe that
NL One was
      not a "blank check company;" however, you should disclose in the filing
that NL One was
      a "shell company" as defined in Rule 12b-2 of the Exchange Act. Please
revise.
        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.

       You may contact James Giugliano at 202-551-3319 or Rufus Decker at
202-551-3769 if
you have questions regarding comments on the financial statements and related
matters. Please
 Nirajkumar Patel
Quick Start Holdings, Inc.
April 5, 2019
Page 2

contact Pam Howell at 202-551-3357 or Brigitte Lippmann at 202-551-3713 with
any other
questions.



                                                        Sincerely,
FirstName LastNameNirajkumar Patel
                                                        Division of Corporation
Finance
Comapany NameQuick Start Holdings, Inc.
                                                        Office of Beverages,
Apparel and
April 5, 2019 Page 2                                    Mining
FirstName LastName