United States securities and exchange commission logo November 16, 2021 G. Reed Petersen President Entertainment Holdings, Inc. 3625 Cove Point Dr. Salt Lake City, Utah 84109 Re: Entertainment Holdings, Inc. Amended Registration Statement on Form 10-12g Filed November 3, 2021 File No. 000-56317 Dear Mr. Petersen: We have reviewed your 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. Amended Registration Statement on Form 10-12g filed on November 3, 2021 General 1. We note that the Form 10-Q for the quarter ended September 30, 2021 was due November 15, 2021. Please file this quarterly report. G. Reed Petersen FirstName LastNameG. Entertainment Holdings,Reed Inc. Petersen Comapany 16, November NameEntertainment 2021 Holdings, Inc. November Page 2 16, 2021 Page 2 FirstName LastName Item 10. Recent Sales of Unregistered Securities, page 25 2. We partially reissue comment 2. Please revise to provide the disclosure required by Item 701 of Regulation S-K for the issuance of securities in the domiciliary merger, as referenced in footnote 1 to the financial statements, including the exemption relied upon and the facts supporting your reliance upon the exemption. 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 William Demarest at 202-551-3432 or Robert Telewicz at 202-551- 3438 if you have questions regarding comments on the financial statements and related matters. Please contact Gregory Herbers at 202-551-8028 or Pam Howell at 202-551-3357 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Jacob Heskett