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                             July 2, 2020

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

                                                        Re: GenTech Holdings,
Inc.
                                                            Offering Statement
on Form 1-A
                                                            Post-Qualification
Amendment No. 2
                                                            Filed June 19, 2020
                                                            File No. 024-11055

       Dear Mr. Lovatt:

              We have reviewed your amendment 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.

       Post-Offering Statement on Form 1-A

       Cover Page

   1.                                                   We note you are
offering 14.5 billion shares of common stock but your amended Articles
                                                        of Incorporation
indicate that the number of authorized shares of common stock is 5
                                                        billion. Please advise
or ensure that you are not offering shares that exceed the number of
                                                        authorized shares.
 David Lovatt
GenTech Holdings, Inc.
July 2, 2020
Page 2
Note 9. Subsequent Events, page F-15

2.     Please tell us how you considered Rule 8-04 and 8-05 of Regulation S-X
in evaluating the
       significance of the Sinister Labs LLC acquisition and whether you are
required to include
       audited financial statement and pro forma information in your POS. As
part of your
       response, provide us with the results of your significance test. Refer
also to Part F/S
       (b)(7)(iii) of Regulation A.
        We will consider qualifying your offering statement at your request. 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 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 Jan Woo,
Legal Branch
Chief, at (202) 551-3453 with any other questions.



                                                             Sincerely,
FirstName LastNameDavid Lovatt
                                                             Division of
Corporation Finance
Comapany NameGenTech Holdings, Inc.
                                                             Office of
Technology
July 2, 2020 Page 2
cc:       William Eilers
FirstName LastName