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                              March 18, 2024

       Rhonda Keaveney
       Chief Executive Officer
       Invech Holdings, Inc.
       7339 E. Williams Drive
       Unit 26496
       Scottsdale, AZ 85255

                                                        Re: Invech Holdings,
Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed March 5, 2024
                                                            File No. 333-276779

       Dear Rhonda Keaveney:

            We have reviewed your amended registration statement and have the
following
       comment(s).

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe a comment applies 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 registration statement and
the information you
       provide in response to this letter, we may have additional comments.
Unless we note otherwise,
       any references to prior comments are to comments in our February 26,
2024 letter.

       Amendment No. 1 to Registration Statement on Form S-1

       Prospectus Summary, page 2

   1.                                                   We note your revised
disclosure pursuant to comment 8 discussing the disparate voting
                                                        rights attached to your
common stock versus your Convertible Series A Preferred Stock as
                                                        well as your disclosure
regarding controlling shareholders and reissue in part. Please
                                                        revise this disclosure
to specifically discuss the risk that the controlling shareholders are
                                                        able to control the
outcome of all matters requiring shareholder approval. We further note
                                                        that you did not
include a risk factor discussing the disparate voting rights and the
                                                        associated risks to
investors. Please revise to include this risk factor.
 Rhonda Keaveney
FirstName  LastNameRhonda Keaveney
Invech Holdings, Inc.
Comapany
March      NameInvech Holdings, Inc.
       18, 2024
March2 18, 2024 Page 2
Page
FirstName LastName

The Offering, page 5

2.       We note your response to prior comment 9 and reissue our comment with
a clarification.
         The number of shares available for resale by the selling stockholders,
3,277,416 shares, is
         not same as the number of shares of common stock outstanding prior to
the offering,
         10,521,335 shares. Please revise to avoid any potential confusion.
Description of Business, page 40

3.       We reissue comment 13 regarding various changes in the corporate name
and nature of
         business. Please revise to provide more detail around the reason for
and nature of such
         changes, the effects such changes had on the company and its
shareholders, the reason the
         company was abandoned in 2007 and any consequential effects, and the
effects the voided
         agreements had on the business.
Consolidated Balance Sheets as of March 31, 2023 and December 31, 2022, page
F-9

4.       We note your response to prior comment 18. Please clarify for us what
you mean by "an
         outside account." Tell us whether this "outside account" is solely
held by Invech Holdings,
         Inc. or held by a third party, an escrow agent, on behalf of Invech
Holdings, Inc. and
         Small Cap Compliance, LLC, and whether there are any obligations that
need to be
         fulfilled before the money is released from the escrow. If the cash
was never restricted,
         tell us why it is still in escrow and was not transferred to the
account of Invech Holdings,
         Inc. when related obligation was fulfilled as the sale of the
preferred shares was on
         January 21, 2023 and the cash is still in escrow as of September 30,
2023, and confirm to
         us that the money belongs to Invech Holdings, Inc. free and clear of
any outstanding
         claims, conditions, obligations, constraints, exceptions and/or
limitations.
General

5.       Please update the financial statements included in the filing in
compliance with Rule 8-08
         of Regulation S-X to include the financial statements for the latest
fiscal year ended as of
         December 31, 2023. Update the associated financial information in
applicable sections of
         the filing as appropriate (e.g. MD&A).
       Please contact Stephen Kim at 202-551-3291 or Joel Parker at
202-551-3651 if you have
questions regarding comments on the financial statements and related matters.
Please contact
Jenna Hough at 202-551-3063 or Donald Field at 202-551-3680 with any other
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Trade
& Services
 Rhonda Keaveney
Invech Holdings, Inc.
FirstName
March 18, 2024 LastNameRhonda Keaveney
Comapany
Page    3      NameInvech Holdings, Inc.
March 18, 2024 Page 3
cc:       Rhonda Keaveney
FirstName LastName