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                             August 13, 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
                                                            Filed July 31, 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-Qualification Amendment to Form 1-A

       General

   1.                                                   Revise to include an
introductory paragraph to your pro forma financial statements with a
                                                        description of the
transaction, including consideration transferred. Also, pro forma
                                                        adjustments should be
referenced to notes that clearly explain the adjustments involved if
                                                        not otherwise clearly
evident. Refer to Part F/S(b)(7)(iii) of Regulation A and Article 11-
                                                        02(b) of Regulation
S-X.
   2.                                                   We note your revised
disclosure that you only have 10 billion shares authorized and do
                                                        not have enough
authorized shares to sell the maximum amount of your offering. Please
                                                        revise to provide a
bona fide estimate of the amount of shares that you will be offering.
                                                        Refer to Rule 253 under
Regulation A.
 David Lovatt
GenTech Holdings, Inc.
August 13, 2020
Page 2
3.     Please file a legality opinion for GenTech Holdings, Inc. We note that
the legality opinion
       that was filed relates to DNA Dynamics, Inc. Ensure that the opinion
covers all the shares
       that are being offered.
        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.

       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
August 13, 2020 Page 2
cc:       William Eilers
FirstName LastName