September 4, 2019

David Lovatt
Chief Executive Officer
GenTech Holdings, Inc.
1731 1st Avenue
New York, NY 10128

       Re: GenTech Holdings, Inc.
           Registration Statement on Form 1-A
           Filed August 8, 2019
           File No. 024-11055

Dear Mr. Lovatt:

       We have reviewed your offering statement 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 this letter by amending your offering statement and
providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response. After reviewing any amendment to your offering statement and the
information you
provide in response to these comments, we may have additional comments.

Registration Statement on Form 1-A

Risk Factors, page 4

1.    Please remove all references to lines of business that do not pertain to
the company's
      future or former lines of business. In this regard we note references to
the action camera
      industry and action online retail business.
2.    Please add a risk factor discussing any regulatory approvals or licensing
required to
      operate in the CBD-infused products market, including the CBD-infused
food market, and
      how you plan to source the CBD. Please add similar disclosure in your
Business section
      where you discuss applicable regulations.
Plan of Distribution
Terms of the Offering, page 29

3.    Please revise to accurately reflect the number of shares being offered.
 David Lovatt
GenTech Holdings, Inc.
September 4, 2019
Page 2
General

4.     We note your statement on page 6 and elsewhere that you are a "publicly
reporting
       company" subject to reporting requirements. We also note your statement
on page 13 that
       you are a non-reporting company. It appears your company will have no
continuing
       reporting obligation following consummation of this Tier I Regulation A
offering and that
       your references to your being a public company with a continuing
reporting obligation are
       not appropriate. Please revise or advise.
        We will consider qualifying your offering statement at your request. In
connection with
your request, please confirm in writing that at least one state has advised you
that it is prepared
to qualify or register your offering. If a participant in your offering is
required to clear its
compensation arrangements with FINRA, please have FINRA advise us that it has
no objections
to the compensation arrangements prior to qualification.

        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 David Edgar, Staff Accountant, at (202) 551-3459 or
Kathleen Collins,
Accounting Branch Chief, at (202) 551-3499 if you have questions regarding
comments on the
financial statements and related matters. Please contact Michael C. Foland,
Attorney-Advisor, at
(202) 551-6711 or Maryse Mills-Apenteng, Special Counsel, at (202) 551-3457
with any other
questions.



                                                             Sincerely,

FirstName LastNameDavid Lovatt                               Division of
Corporation Finance
                                                             Office of
Information Technologies
Comapany NameGenTech Holdings, Inc.
                                                             and Services
September 4, 2019 Page 2
cc:       William Eilers
FirstName LastName