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                              May 20, 2021

       David Lovatt
       Chief Executive Officer
       GenTech Holdings, Inc.
       1731 First Avenue, Suite 25955
       New York, NY 10128

                                                        Re: GenTech Holdings,
Inc.
                                                            Post-Qualification
Amendment on Form 1-A
                                                            Filed May 11, 2021
                                                            File No. 024-11055

       Dear Mr. Lovatt:

              We have reviewed your amendment 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.

       Post-Qualification Amendment on Form 1-A filed May 11, 2021

       General

   1.                                                   Your offering circular
cover page states that this offering is for a maximum of 20 billion
                                                        shares while Item 4 of
Form 1-A and page 3 state that it is for a maximum of 24 billion
                                                        shares. Please revise
to reconcile this discrepancy.
   2.                                                   Please note that for
Tier 1 offerings, the sum of all cash and other consideration to be
                                                        received for the
securities being offered plus the gross proceeds for all securities sold
                                                        pursuant to other
offering statements within the 12 months before the start of and during
                                                        the current offering of
securities may not exceed $20 million. See Rule 251(a)(1) of
                                                        Regulation A.
Accordingly, please revise to:

                                                              Disclose the
amount you have already sold in this and other offerings within the past
                                                            12 months. For
example, we note that a prior post-qualification amendment was
                                                            qualified on
September 30, 2020 for an offering amount of $3,564,700.
 David Lovatt
GenTech Holdings, Inc.
May 20, 2021
Page 2


             Ensure that the price range for this current offering is in
compliance with Rule
           251(a)(1). In this regard, we note your disclosure that the price
per share will be
           fixed at a price between $0.0005 and $0.003. We further note that
some of the prices
           within this range would result in proceeds in excess of $20 million.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
19

3.     We note that you generated $253,173 in revenue for the fiscal year ended
October 31,
       2020. Please revise this section to provide a narrative discussion of
how you generated
       this revenue.
        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.

      Please contact Mitchell Austin, Staff Attorney, at (202) 551-3574 or, in
his absence, Jan
Woo, Legal Branch Chief, at (202) 551-3453 with any questions.



                                                             Sincerely,
FirstName LastNameDavid Lovatt
                                                             Division of
Corporation Finance
Comapany NameGenTech Holdings, Inc.
                                                             Office of
Technology
May 20, 2021 Page 2
cc:       Donnell Suares
FirstName LastName