UNEX HOLDINGS INC
Ul. Sveti Kliment Ohridski 27, Apt. 8, Burgas, Bulgaria 8000, Tel. +359-884303333
February 7, 2019
VIA EDGAR
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Attention: Mr. Edward Kelly
Unex Holdings Inc.
Registration Statement on
Form S-1 (File No. 333-228161)
Dear Mr. Edward Kelly:
Pursuant to Rule 461(a) of the Securities Act of 1933, as amended, Unex Holdings Inc. (the Company) hereby requests that the effective date of the above-captioned Registration Statement on Form S-1 of the Company be accelerated to Monday, February 11, 2019 at 1:00 p.m. Eastern Time, or as soon thereafter as may be practicable.
The Company hereby acknowledges that:
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should the Commission or the staff of the Commission (the Staff), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;
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the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and
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the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
We understand that the Staff will consider this request as confirmation by the Company of its awareness of its responsibilities under the federal securities laws as they relate to the issuance of the securities covered by the Registration Statement.
Very truly yours,
By: |
| /s/ | Veniamin Minkov |
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| Name: | Veniamin Minkov |
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| Title: | President, Director, Treasurer and Secretary | ||
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| (Principal Executive, Financial and Accounting Officer) |