September 9, 2020




United States Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549



Xalles Holdings Inc.

Withdrawal of Form 1-A

Filed March 24, 2020

File No. 024-11182


Ladies and Gentlemen:


On behalf of Xalles Holdings Inc., a Nevada Corporation (the “Company”), we hereby request that the offering on Form 1-A (File No. 024-11182) as filed with the Securities and Exchange Commission (the “Commission”) on March 24, 2020 be withdrawn, effective the date of this letter.


Accordingly, we request that the Commission issue an order granting the withdrawal of the Amendment(s) effective as of the date hereof or at the earliest practicable date hereafter. Please provide a copy of the order or notice to William Eilers of Eilers Law Group, P.A., via email at


The Company plans to complete some audits to return to Fully SEC Reporting status and then subsequently file a new Form 1-A for a Tier II offering.


If you have any questions or comments regarding this request or require any additional information, please do not hesitate to contact Eilers Law Group, P.A. at (786) 273-9152.



    /s/ Thomas W. Nash
  Thomas W. Nash, CEO






Xalles (PK) (USOTC:XALL)
Historical Stock Chart
From Aug 2021 to Sep 2021 Click Here for more Xalles (PK) Charts.
Xalles (PK) (USOTC:XALL)
Historical Stock Chart
From Sep 2020 to Sep 2021 Click Here for more Xalles (PK) Charts.