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                               April 5, 2021

       Deanna Johnson
       Chief Executive Officer
       Fuel Doctor Holdings, Inc.
       410 Louisiana Street
       Vallejo, CA 94590

                                                        Re: Fuel Doctor
Holdings, Inc.
                                                            Registration
Statement on Form 10-12G
                                                            Filed March 8, 2021
                                                            File No. 000-56253

       Dear Ms. Johnson:

              We have reviewed your filing 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 these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Registration Statement on Form 10-12G filed March 8, 2021

       Item 4. Security Ownership of Certain Beneficial Owners and Management.
       Principal Stockholders, page 8

   1.                                                   Please amend your
disclosure to identify the natural person(s) with voting and/or
                                                        dispositive power over
the shares owned by Friction & Heat, LLC. Please also provide
                                                        the addresses of the
entities listed in the table. See Item 403(a) of Regulation S-K.
       Item 7. Certain Relationships and Related Transactions., page 10

   2.                                                   We note your references
throughout your filing and in your financial statements to loans
                                                        with related parties.
Please amend your disclosure to describe the material terms of any
                                                        loans with related
parties for the periods presented in your filing, including the identity of
                                                        the parties and the
amount of the loan. See Item 404(a) of Regulation S-K.
 Deanna Johnson
FirstName
Fuel DoctorLastNameDeanna
             Holdings, Inc. Johnson
Comapany
April       NameFuel Doctor Holdings, Inc.
       5, 2021
April 25, 2021 Page 2
Page
FirstName LastName
Item 9. Market Price of, and Dividends on, the Registrant's Common Equity and
Related
Stockholder Matters.
(a) Market Information, page 10

3.       You disclose that your common stock trades on the OTC Pink. Please
amend your
         disclosure here to inform investors that the OTC Pink includes
warnings to "STOP"
         and that your common stock is "Dark or Defunct," and describe for
investors the meaning
         of such designations.
(d) Equity Compensation Plan Information, page 10

4.       We note your disclosure that "the Company has granted shares of
restricted stock to its
         officers, directors and others for services periodically and as part
of some of the officers
         employment agreements." However, your disclosure on page 9 states that
"[t]he
         Company does not have employment agreements with any of its officers
or directors," and
         your Summary Compensation table and other executive compensation
disclosure does not
         include a discussion of restricted stock awards. Please amend your
filing to reconcile
         these disclosures.
General

5.       We note your disclosures that "[n]o revenue has been generated by the
Company,"
         and "[i]t is unlikely the Company will have any revenues unless it is
able to effect an
         acquisition or merger with an operating company, of which there can be
no assurance."
         We also note that you appear to have nominal assets. Therefore, it
appears that you are
         a shell company as defined in Rule 12b-2 of the Exchange Act. Please
amend your filing
         to prominently disclose your shell company status and disclose the
consequences of that
         status, including details regarding compliance with Rule 419 in
connection with any
         offering of your securities, the prohibition on the use of Form S-8 by
shell companies,
         enhanced reporting requirements imposed on shell companies, and the
conditions that
         must be satisfied before restricted and control securities may be
resold in reliance on Rule
         144.
6.       Please be advised that your registration statement will automatically
become effective
         sixty days after filing. Upon effectiveness, you will become subject
to the reporting
         requirements of the Securities Exchange Act of 1934, even if we have
not cleared your
         comments. If you do not wish to incur those obligations until the
review process is
         completed, you may wish to consider withdrawing your registration
statement and
         resubmitting a new registration statement when you have revised your
document.
 Deanna Johnson
FirstName
Fuel DoctorLastNameDeanna
             Holdings, Inc. Johnson
Comapany
April       NameFuel Doctor Holdings, Inc.
       5, 2021
April 35, 2021 Page 3
Page
FirstName LastName
        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.

        You may contact Aamira Chaudhry at 202-551-3389 or Angela Lumley at
202-551-
3398 if you have questions regarding comments on the financial statements and
related
matters. Please contact Katherine Bagley at 202-551-2545 or Dietrich King at
202-551-
8071 with any other questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Trade &
Services
cc:      Stephen Mills