SecProbe.io

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 April 30, 2025

Mack Leath
Chief Executive Officer
Mitesco, Inc.
505 Beachland Blvd., Suite 1-377
Vero Beach, Florida 32963

 Re: Mitesco, Inc.
 Registration Statement on Form S-1
 Filed April 18, 2025
 File No. 333-286619
Dear Mack Leath:

 We have conducted a limited review of your registration statement and
have the
following comments..

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies 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 registration statement and the
information
you provide in response to this letter, we may have additional comments.

Registration Statement on Form S-1
General

1. We note that your common stock is quoted on the Pink Market. On page 6,
you
 disclose that the selling stockholders may offer or sell the shares
covered by this
 registration statement through public or private transactions at
prevailing market
 prices, at prices related to prevailing market prices or at privately
negotiated
 prices. Please note that an at-the-market resale offering under Rule 415
is not
 available for registrants quoted on the Pink Market, because the Pink
Market is not an
 established trading market for purposes of satisfying Item 501(b)(3) of
Regulation S-
 K. Please revise here and elsewhere to disclose a fixed price at which
the selling
 shareholders will offer and sell their shares until your shares are
listed on a national
 securities exchange or quoted on the OTC Bulletin Board, OTCQX, or
OTCQB, at
 which time they may be sold at prevailing market prices.
 April 30, 2025
Page 2

Exhibits

2. The auditor consent filed as Exhibit 23.1 states that the auditor
consents to the use of
 its report dated March 31, 2025, relating to its audit of the company
"for the period
 January 1 to December 31, 2024." Please file a revised auditor consent
that clarifies
 that the referenced audit report covers to the audit of the company for
the periods of
 January 1, 2023 to December 31, 2023 and January 1, 2024 to December 31,
2024.
Signatures, page 62

3. We note that the text of the Signatures section includes a reference to
the requirements
 of the Securities Exchange Act of 1934. Please revise this reference to
refer to the
 requirements of the Securities Act of 1933.
 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.

 Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

 Please contact Mitchell Austin at 202-551-3574 or Jan Woo at
202-551-3453 with any
other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Technology
cc: Joel D. Mayersohn
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