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May 23, 2023
Dante Picazo
Chief Executive Officer
Cannabis Bioscience International Holdings, Inc.
6201 Bonhomme Road
Suite 466S
Houston, TX 77036
Re:Cannabis Bioscience International Holdings, Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed April 27, 2023
File No. 333-267039
Dear Dante Picazo:
            We have reviewed your amended registration statement 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our February 8, 2023 letter.
Amendment No. 2 to Registration Statement on Form S-1 Filed April 27, 2023
Risk Factors, page 8
1.We note your response to comment 2. Given that the Pharmacology University Business
is dependent upon the existence of a national and international cannabis market, please
include disclosure that describes the cannabis-related laws of each of the states, territories
and countries in which you operate, as well as the associated risks to your company and
investors. Also, given your disclosure that you have resumed classes in only Texas and
Colombia, please clarify your discussion of your "operations and... personnel outside the
United States in Mexico, Jordan, Ecuador..., Venezuela, Argentina  and Brazil."

 FirstName LastNameDante Picazo
 Comapany NameCannabis Bioscience International Holdings, Inc.
 May 23, 2023 Page 2
 FirstName LastName
Dante Picazo
Cannabis Bioscience International Holdings, Inc.
May 23, 2023
Page 2
2.We note your disclosure on page 36 that you have been experiencing delays in payments
by Sponsors and CROs. To the extent this has had, has or will have a material impact on
your business, please include appropriate risk factor disclosure.
Dilution, page 30
3.Please reconcile the disclosure of 8,846,919,983 shares outstanding prior to the offering
with the disclosure of 10,034,677,919 shares on page 7.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources, page 36
4.Please revise the second paragraph on page 36 so disclosure of total revenue and accounts
receivable for all periods presented agrees to the amounts reported in the financial
statements. For instance, you disclose total revenues for the six months ended $219,162 in
this section, but reported $214,980 on the Statements of Operations on page F-18.
Description of Business, page 37
5.We note your response to comment 5. Please revise to clarify whether your investigators
are employees of the company or have a different employment relationship with the
company. In addition, please revise the disclosure in the Business section to provide the
total number of full-time and part-time employees that you employ. In this regard we note
that the current disclosure on page 44 identifies employees for the "Alpha Research"
portion of your business. Refer to Item 101(h)(4)(xii) of Regulation S-K.
Education Services, page 41
6.We note your response to comment 10 and your disclosure that your courses provide
"CME and CLE credits." Please clarify which professional organizations have approved
your courses for CME and CLE credit and which state(s) has made CME and CLE credits
available for doctors and lawyers taking your classes.
Plan of Distribution, page 66
7.We note your response to comment 13 and reissue in part.  Revise your statement that you
"may offer unregistered shares of Common Stock to investors in private placements at
prices per share that may be higher or lower than the public offering price" to clarify that
this may be done only if federal securities laws, including Rule 152 under the Securities
Act, permit you to do so.
Index to Consolidated Financial Statements, page 71
8.Please update your interim financial statements in accordance with Rule 8-08 of
Regulation S-X.

 FirstName LastNameDante Picazo
 Comapany NameCannabis Bioscience International Holdings, Inc.
 May 23, 2023 Page 3
 FirstName LastName
Dante Picazo
Cannabis Bioscience International Holdings, Inc.
May 23, 2023
Page 3
Note 2 - Summary of Significant Accounting Policies
Revenue Recognition, page F-22
9.We note you did not include a response to comment 15, so we are re-issuing this
comment.  Please disclose the significant payment terms on your contracts, such as when
payment typically is due and whether the contract has a significant financing component.
Refer to ASC 606-10-50-12. This comment also applies to the interim financial
statements.
10.We note your response to comment 16, but are unable to locate the revised disclosure on
page F-6 or F-22.  Please advise or otherwise revise to disclose how you account for
contract modifications. If you have different accounting policies for different types of
modifications, please disclose all policies and when they are applicable.

11.We note your response to comment 17, but are unable to locate the revised disclosure.
Please advise or otherwise disclose, as applicable, information about remaining
performance obligations at the end of the period in accordance with ASC 606-10-50-13.
Exhibits
12.Please file an English translation of Exhibit 10.10. Refer to Exchange Act Rule 12b-
12(d)(2).
Exhibit 5.1
13.It appears that the revised opinion continues to identify an incorrect number of shares
being offered by the company.  Please revise or advise.
            You may contact Ta Tanisha Meadows at 202-551-3322 or Theresa Brillant at 202-551-
3307 if you have questions regarding comments on the financial statements and related
matters.  Please contact Nicholas Nalbantian at 202-551-7470 or Lilyanna Peyser at 202-551-
3222 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Barry J. Miller