United States securities and exchange commission logo





                             August 5, 2021

       Teresa McWilliams
       Chief Executive Officer
       Aluf Holdings, Inc.
       4801 South University Drive, Suite 227
       Fort Lauderdale, FL 33328

                                                        Re: Aluf Holdings, Inc.
                                                            Offering Statement
on Form 1-A
                                                            Filed July 29, 2021
                                                            File No. 024-11592

       Dear Ms. McWilliams:

                                                        This is to advise you
that we do not intend to review your offering statement.

               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.

               Please contact Priscilla Dao, Staff Attorney, at (202) 551-5997
or Jan Woo, Legal Branch
       Chief, at (202) 551-3453 with any questions.




                             Sincerely,


                             Division of Corporation Finance

                             Office of Technology
       cc:                                              John E. Dolkart, Jr.