SecProbe.io

CORRESP
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NEWHYDROGEN,
INC.

27936
Lost Canyon Road, Suite 202

Santa
Clarita, CA 91387

May
20, 2022

Via
Edgar Correspondence

Division
of Corporate Finance

Office
of Manufacturing

U.S.
Securities and Exchange Commission

100
F Street, NE

Washington,
D.C. 20549

Attn:
Dale Welcome and Anne McConnell

    Re:
    NewHydrogen,
    Inc.

    Form
    10-K for the Fiscal Year Ended December 31, 2021 Filed March 31, 2022

    File
    No. 000-54819

To
whom it may concern:

On
behalf of NewHydrogen, Inc. (the “Company”), please find below our response to the comment raised by the staff (the “Staff”)
of the Securities and Exchange Commission in its letter dated May 17, 2022 relating to the Company’s Form 10-K for the Fiscal Year
Ended December 31, 2021 filed March 31, 2022.

For
your convenience, the Staff’s comment has been restated and is followed by the Company’s response.

Form
10-K for the Fiscal Year Ended December 31, 2021

Report
of Independent Registered Public Accounting Firm, page F-1

    1.
    Please amend your Form 10-K to include a revised auditor’s report that addresses the following:

    ●
    Ensure
    the auditors’ report is dated as required by AS 3101.10(d) and Rule 2-02(a) of Regulation S-X; and

    ●
    Ensure
    the auditors’ report adequately describes how the critical audit matter was addressed in the audit and refers to the relevant
    financial statement disclosures that relate to the critical audit matter as required by AS 3101.14(c) and (d). In this regard, it
    appears stock compensation expense may relate to transactions in addition to stock options.

    We
    remind you that your amended filing should include updated certifications that are currently dated and refer to the Form 10-K/A.

RESPONSE:
The Company has amended its Form 10-K to include a revised auditor’s report that includes (i) the date as required by AS 3101.10(d)
and Rule 2-02(a) of Regulation S-X and (ii) a detailed description of how the critical audit matter was addressed in the audit and reference
to the relevant financial statements that relate to the critical audit matter as required by AS 3101.14(c) and (d).

Should
you have additional questions regarding the information contained herein, please contact our counsel, Marcelle Balcombe at (212) 930-9700
or mbalcombe@srf.law.

    Sincerely,

    /s/
    David Lee

    David
    Lee

    Chief
    Executive Officer