IVHI Invech Holdings Inc (PK)

DELAYING AMENDMENT LETTER

INVECH HOLDINGS, INC.

January 31, 2024

Via EDGAR

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Re: Invech Holdings, Inc. Registration Statement on Form S-1 (File No. 333-276779) filed on January 31, 2024.

Ladies and Gentlemen:

Reference is made to the Registration Statement on Form S-1 (File No. 0000-25553) filed by Invech Holdings, Inc. on January 31, 2024 (the “Registration Statement”).

Pursuant to Rule 473(c) of the Securities Act of 1933, as amended (the “Act”), the following delaying amendment, prescribed by Rule 473(a) of the Act, is hereby incorporated onto the facing page of the Registration Statement immediately following the calculation of registration fee table:

“The registrant hereby amends this registration statement on such date or dates as may be necessary to delay its effective date until the registrant shall file a further amendment which specifically states that this registration statement shall thereafter become effective in accordance with Section 8(a) of the Securities Act of 1933, as amended, or until this registration statement shall become effective on such date as the SEC, acting pursuant to said Section 8(a) may determine.”

Should you have any questions regarding the Registration Statement, please feel free to contact the undersigned at (602) 793-8058.

Yours sincerely,

/s/ Rhonda Keaveney

CEO, Invech Holdings, Inc.

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