United States securities and exchange commission logo March 14, 2023 Farid Shouekani Chief Executive Officer Viper Networks Inc 200 E Big Beaver Rd. Troy, MI 48083 Re: Viper Networks Inc Post-Qualification Amendment No. 1 to Offering Statement on Form 1-A Filed March 9, 2023 File No. 024-11948 Dear Farid Shouekani: 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 Nicholas Nalbantian at 202-551-7470 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Jeff Turner