United States securities and exchange commission logo





                              November 15, 2022

       Vikram Grover
       Chief Executive Officer
       Himalaya Technologies, Inc.
       1 E. Erie St., Ste. 525, Unit #2420
       Chicago, IL 60611

                                                        Re: Himalaya
Technologies, Inc.
                                                            Amendment No. 4 to
Offering Statement on Form 1-A
                                                            Filed November 2,
2022
                                                            File No. 024-11980

       Dear Vikram Grover:

             We have reviewed your amended 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.

       Amendment No. 4 to Offering Statement on Form 1-A filed November 2, 2022

       Our Business, page 8

   1.                                                   We note your disclosure
that on October 28, 2022 you signed a purchase agreement to
                                                        acquire the assets of a
company that provides training software for the agriculture sector.
                                                        Please provide us with
your analysis related to the significance of this acquisition
                                                        and whether you are
required to include audited financial statements and pro forma
                                                        information. Refer to
Part F/S of Form 1-A and Rules 8-04 and 8-05 of Regulation S-X.
 Vikram Grover
FirstName LastNameVikram
Himalaya Technologies, Inc. Grover
Comapany 15,
November  NameHimalaya
              2022        Technologies, Inc.
November
Page 2    15, 2022 Page 2
FirstName LastName
      You may contact Cheryl Brown, Staff Attorney, at (202) 551-3905 or Loan
Lauren
Nguyen, Legal Branch Chief, at (202) 551-3642 with any questions.



                                                       Sincerely,

                                                       Division of Corporation
Finance
                                                       Office of Energy &
Transportation
cc:      Milan Saha, Esq.