United States securities and exchange commission logo March 15, 2023 Calvin D. Smiley, Sr. Chief Executive Officer VECTOR 21 HOLDINGS, INC. 9605 W. 49th Ave., #200 Wheat Ridge, CO 80033 Re: VECTOR 21 HOLDINGS, INC. Amendment No. 2 to Registration Statement on Form 10-12G Filed March 9, 2023 File No. 000-56418 Dear Calvin D. Smiley: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Christen Lambert