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                           January 12, 2023

       Vikram Grover
       Chief Executive Officer
       Himalaya Technologies, Inc.
       1 E. Erie St., Ste. 525, Unit #2420
       Chicago, IL 60611

                                                        Re: Himalaya
Technologies, Inc.
                                                            Amendment No. 6 to
Offering Statement on Form 1-A
                                                            Filed December 21,
2022
                                                            File No. 024-11980

       Dear Vikram Grover:

             We have reviewed your amended offering statement and have the
following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by amending your offering statement
and providing the
       requested information. If you do not believe our comments apply 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 offering statement and the
information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
December 15, 2022 letter.

       Amendment No. 6 to Offering Statement on Form 1-A filed December 21,
2022

       Our Business, page 5

   1.                                                   We understand from your
December 4, 2022 and January 5, 2023 response letters that you
                                                        do not believe
financial statements of Business Media Solutions, Inc. (d/b/a Russell
                                                        Associates) are
required in the Form 1-A pursuant to Rule 8-04 of Regulation S-X, as
                                                        referenced in paragraph
(b)(7)(iii) of Part F/S of Form 1-A, notwithstanding your having
                                                        executed a purchase
agreement on October 19, 2022, and an amendment to the purchase
                                                        agreement on November
25, 2022, which were both filed as exhibits to your Form 1-A on
                                                        November 2, 2022 and
November 29, 2022, respectively, and reported in press releases
                                                        and on Form 8-K
November 1, 2022, November 2, 2022, and November 28, 2022.
 Vikram Grover
FirstName  LastNameVikram
Himalaya Technologies, Inc. Grover
Comapany
January 12,NameHimalaya
            2023          Technologies, Inc.
January
Page 2 12, 2023 Page 2
FirstName LastName
         In your earlier reply, you indicated that because the contract did not
include substantive
         penalties for non-compliance, you considered the arrangement
effectively a non-binding
         letter of intent    and were therefore relying on a    general rule of
thumb    that suggests a
         letter-of-intent alone is not conclusive in assessing the need to
provide financial
         statements, and you further clarified that presuming the    legal
status of the transaction as a
         non-binding LOI was critical to [your] analysis   .

         However, the original agreement and the amendment to the agreement
both include the
         language    upon acceptance of this contract, Seller shall sell and
Buyer shall purchase, the
         business,       The undersigned hereby agree to execute any and all
documents necessary to
         close this transaction,    and    This is a Legally Binding and Fully
Enforceable Contract,    in
         addition to establishing the amount and form of consideration, and the
closing date.

         We note that you provide disclosures of the salient terms of the
arrangement in the Form
         1-A, also in referring to the target, the statement    Over the past
few years, the business
         generated annual revenues of roughly $500,000 in agriculture/food
markets,    and you
         indicate that you would use offering proceeds to complete the
transaction.

         Your plans and intentions were also expressed by your CEO in the press
releases that you
         filed concerning the pending acquisition, in stating    This planned
transaction provides our
         Company accretive revenues and margin, a platform for growth and
expansion into high
         growth markets, and potential synergies with our portfolio of
investments and for our
         affiliate Company FOMO CORP.   s education technology and clean
technology
         subsidiaries. We intend to build off this Target   s critical mass and
rolodex in agriculture
         and food markets and expand into new verticals to multiply its scope
and scale.

         In your more recent reply, you explain that you replaced the purchase
agreement with a
         letter-of-intent on December 19, 2022, and reiterate the view that
because it is non-
         binding, having    no break-up fees or penalties for failure to close,
   you do not believe that
         financial statements should be required. We see that you filed the new
agreement with
         your recent amendment, and that while some of the language has been
modified to more
         clearly accommodate the optionality emphasized in your response, i.e.
to endure no
         penalty in the event you do not proceed, the terms and provisions
governing the
         acquisition otherwise appear to be consistent with the original
purchase agreement.

         Given the sequence and content of the filings referenced above and
considering the
         significance of the pending transaction, we do not find persuasive
your view that being
         able to not proceed without penalty would render the financial
statements of Business
         Media Solutions, Inc. (d/b/a Russell Associates) as not material to an
investment
         decision. Under the circumstances, we believe that such financial
statements would
         represent material information that is necessary to make the required
statements contained
         in the offering statement, in light of the circumstances under which
they are made, not
         misleading, and therefore required pursuant to Rule 252(a) of
Regulation A.
 Vikram Grover
FirstName  LastNameVikram
Himalaya Technologies, Inc. Grover
Comapany
January 12,NameHimalaya
            2023          Technologies, Inc.
January
Page 3 12, 2023 Page 3
FirstName LastName
2.       Please expand your disclosure on page 8 to describe the evolution of
the arrangement to
         acquire Business Media Solutions, Inc. (d/b/a Russell Associates),
including the various
         dates and forms of the agreement, along with the reasons for replacing
the purchase
         agreement with a letter-of-intent. Also describe any material
uncertainties regarding your
         ability to proceed with the acquisition, and any information that you
have yet to obtain
         that could diminish your interest in completing the acquisition, along
with an indication of
         the timeframe and the manner by which you expect to resolve these
concerns.
Risk Factors, page 9

3.       We note disclosure on page 22 stating that you have retained
independent professionals,
               including Boyle CPA, LLC our prior audit firm, and Victor
Mokuolu CPA, LLC, our
         current auditors, to review or comment on this Offering or otherwise
protect the interest of
         the investors hereunder,    while conversely advising investors not to
rely on your counsel
         with respect to any matters described in the offering statement.

         Tell us how the role of the auditors as described in this disclosure
would be consistent
         with maintaining independence, considering the examples in Rule
2-01(c)(4)(i)(B), (iii),
         and (ix) of Regulation S-X, if this is your view.

         Please revise here and on page 42, as appropriate to clarify and
differentiate between the
         responsibilities of the auditors and management for the disclosures
and financial
         statements provided in the offering statement. Please note that the
company and its
         management are responsible for the accuracy and adequacy of their
disclosures.
Use of Proceeds, page 27

4.       Please revise or qualify your disclosure in the last paragraph on page
27, stating that you
               have no present commitments or agreements for any specific
acquisitions or
         investments,    to acknowledge your plans to acquire Business Media
Solutions, Inc. (d/b/a
         Russell Associates), as referenced in the footnote to the preceding
tabulation.
Dilution, page 28

5.       Please modify your disclosure to more clearly address the requirement
to provide a
         comparison of the public contribution under the proposed public
offering and the average
         effective cash cost to officers, directors, promoters and affiliated
persons for shares
         acquired by them during the past year, including shares they have a
right to acquire.

         For example, it appears that you would need to expand your disclosure
to illustrate the
         effects of convertible instruments such as your Class B Preferred
Stock and your Class C
         Preferred Stock, which we understand are convertible into an
incremental 1,545,966,000
         common shares, based on disclosures appearing on page 39.

         Also clarify how the label on the last line of the table, presently
indicating that you have
         computed a figure of accretion    to new investors,    reconciles with
the content of the
 Vikram Grover
Himalaya Technologies, Inc.
January 12, 2023
Page 4
      tabulation and the disclosures preceding the table, indicating new
investors would
      experience dilution in the value of their shares relative to the offering
price.
       You may contact Chery Brown, Staff Attorney, at (202) 551-3905 or Kevin
Dougherty,
Staff Attorney, at (202) 551-3271 with any questions.



                                                           Sincerely,
FirstName LastNameVikram Grover
                                                           Division of
Corporation Finance
Comapany NameHimalaya Technologies, Inc.
                                                           Office of Energy &
Transportation
January 12, 2023 Page 4
cc:       Milan Saha, Esq.
FirstName LastName