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September 18, 2020
Antonio Milici
Chief Executive Officer
GeneThera, Inc.
3051 W 105th Ave. #350251
Westminster, CO 80035
Re:GeneThera, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2019
Filed June 10, 2020
File No. 000-27237
Dear Mr. Milici:
            We have limited our review of your filing to the financial statements and related
disclosures 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2019
Item 9A. Controls and Procedures
Management’s Annual Report on Internal Control over Financial Reporting, page 23
1.Your management’s annual report on internal control over financial reporting refers to
December 31, 2018 in the conclusion sentence.  Please file an amendment to refer to the
current fiscal year as required by Item 308(a)(3) of Regulation S-K.  As a reminder, your
amended filing should include updated certifications that are currently dated and make
reference to the amended Form 10-K.
Financial Statements
Report of Independent Registered Public Accounting Firm, page F-3
2.We note that the report of your independent registered public accounting firm refers to
Beyond Wellness International, Inc.  Please have your auditor revise its audit report in an
amended filing to reflect the name of your company that is included in your financial

 FirstName LastNameAntonio  Milici
 Comapany NameGeneThera, Inc.
 September 18, 2020 Page 2
 FirstName LastName
Antonio  Milici
GeneThera, Inc.
September 18, 2020
Page 2
statements as required by AS 3101.
            In closing, 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.
            You may contact Li Xiao at (202) 551-4391 or Brian Cascio, Accounting Branch Chief,
at (202) 551-3676 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences