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                             May 17, 2021

       Orlando Hernandez
       Chief Executive Officer
       VICTORY MARINE HOLDINGS CORP
       555 NE 34th Street, Suite 1207
       Miami, FL 33137

                                                        Re: VICTORY MARINE
HOLDINGS CORP
                                                            Offering Statement
on Form 1-A
                                                            Filed May 12, 2021
                                                            File No. 024-11525

       Dear Mr. Hernandez:

                                                        This is to advise you
that we do not intend to review your offering statement.

               We will consider qualifying your offering statement at your
request. In connection with
       your request, please confirm in writing that at least one state has
advised you that it is prepared
       to qualify or register your offering. 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
Jacqueline Kaufman at 202-551-3797 with any questions.




                             Sincerely,


                             Division of Corporation Finance

                             Office of Trade & Services