TEXT-EXTRACT 2 filename2.txt November 7, 2019 David Lovatt Chief Executive Officer GenTech Holdings, Inc. 1731 1st Avenue New York, NY 10128 Re: GenTech Holdings, Inc. Offering Statement on Form 1-A Post-qualification Amendment No. 1 Filed October 29, 2019 File No. 024-11055 Dear Mr. Lovatt: We have reviewed your amendment and do not have any comments. We will consider qualifying your offering statement at your request. If a participant in your offering is required to clear its compensation arrangements with FINRA, please have FINRA advise us that it has no objections to the compensation arrangements prior to qualification. 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 Michael C. Foland, Attorney-Advisor, at (202) 551-6711 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: William Eilers