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Barry J. Miller

7146 Pebble Park
Drive

West Bloomfield,
Michigan 48322

Tel.: +1 (248) 232-8039

Fax: +1 (248) 246-9524

E-Mail: bjmiller@bjmpllc.com

November 13, 2023

U.S. Securities and Exchange Commission

Washington, D.C. 20549

    Re:
    Cannabis Bioscience International Holdings, Inc.

    Registration Statement on Form S-1 (File No. 333-267039) – Amendment
    No. 6

On behalf of my
client, Cannabis Bioscience International Holdings, Inc. (the “Company”), I am responding to the comments from your Staff
(the “Staff”) relating to Amendment No. 5 to the referenced Registration Statement (the “Registration Statement”)
contained in the Staff’s letter dated October 19, 2023. In response to these comments, the Company has today filed Amendment No.
6 to the Registration Statement.

Set forth below
is the Company’s response to the Staff’s comments. For convenience, the Staff’s comments are repeated below in italics,
followed by the Company’s response and a summary of the responsive actions taken.

Comment
1:

Description of Business

Clinical Trial in Which We Will be
the Sponsor, page 56

Please identify
the Harvard Health Publishing article you refer to in this sub-section.

Response:

The article has been identified
in the specified text.

Comment 2:

We note your disclosure
that "CBD derived from hemp containing less than 0.3% of tetrahydrocannabinol...was legalized at the federal level by the Agriculture
Improvement Act of 2018 and its sale and use of CBD products containing less than 0.3% of THC is legal in all states except for 18, which
restrict sale and use for various reasons, including the age of the purchaser, non-medical use and the THC content." Please tell
us your plans regarding the potential sale of such products in the 18 states that restrict its sale and use.

Response:

The text
has been updated to indicate that the Company does not plan to sell CBD products in these 18 states or in any jurisdiction in which their
sale would be illegal.

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Comment 3:

Notes to Consolidated
Financial Statements Note 4 - Debt

PPP Loans, page F-12

Please
address the following discrepancies between the disclosures in this footnote and the amounts disclosed in the Consolidated Statements
of Operations and the Consolidated Statements of Cash Flows:

 · You
                                            state the balance of the PPP loans at May 31, 2023 is $41,666 is recorded in Current Liabilities,
                                            but the balance sheet shows a balance of $0 at May 31, 2023.

 · You
                                            state you received forgiveness for the PPP loans in April 2021. Please explain what the 2022
                                            and 2023 amounts represent in the line item “Forgiveness of PPP loan” on the
                                            Statements of Cash Flows.

Response:

 · This
                                            statement was incorrect and has been removed.

 · The
                                            forgiveness of PPP loans was erroneously included in the Company’s consolidated statements
                                            of cash flows for the fiscal years ended May 31, 2023, and May 31, 2022. These statements
                                            have been amended by removing these line items.

The amendment also
contains unaudited financial statements for the quarter ended August 31, 2023, material in Management’s Discussion relating to
these financial statements and other updating or clarifying changes.

Please contact
me if you have any questions regarding the foregoing or if I can provide any additional information.

Very
truly yours,

/s/
Barry J. Miller

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