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                             April 17, 2024

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

                                                        Re: Invech Holdings,
Inc.
                                                            Amendment No. 3 to
Registration Statement on Form S-1
                                                            Filed April 9, 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 April 2, 2024
letter.

       Amendment No. 3 to Registration Statement on Form S-1 Filed April 9,
2024

       Item 16. Exhibits and Financial Statement Schedules, page F-1

   1.                                                   We note your response
to our prior comment 2 and related revisions and reissue our
                                                        comment with a
clarification. Please revise to eliminate the label "unaudited" throughout
                                                        pages F-3 through F-9
as they represent audited financial statements and related notes. See
                                                        the bottom of pages F-3
through F-6 and Notes 2, 3, and 6 on pages F-7 through F-9.
       General

   2.                                                   We note your response
to prior comment 4 and reissue our comment in entirety. Please
                                                        have your auditor
provide an updated consent to reflect the appropriate report date and
                                                        periods presented in
the financial statements included in the filing.
 Rhonda Keaveney
Invech Holdings, Inc.
April 17, 2024
Page 2

       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.



FirstName LastNameRhonda Keaveney                        Sincerely,
Comapany NameInvech Holdings, Inc.
                                                         Division of
Corporation Finance
April 17, 2024 Page 2                                    Office of Trade &
Services
FirstName LastName