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November 14, 2022
Timothy G. Dixon
President and Chief Executive Officer
Therapeutic Solutions International, Inc.
701 Wild Rose Lane
Elk City , Idaho 83525
Re:Therapeutic Solutions International, Inc.
Registration Statement on Form S-1
Filed October 31, 2022
File No. 333-268070
Dear Timothy G. Dixon:
            We have limited our review of your registration statement to those issues we have
addressed in our 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.
Form S-1 filed October 31, 2022
Cover Page
1.Please amend your filing to name GHS Investments, LLC as an underwriter and selling
shareholder. At a minimum, this disclosure should appear to the prospectus cover page
and in the plan of distribution. For guidance, refer to Securities Act Compliance and
Disclosure Interpretation 139.13.

 FirstName LastNameTimothy G. Dixon
 Comapany NameTherapeutic Solutions International, Inc.
 November 14, 2022 Page 2
 FirstName LastNameTimothy G. Dixon
Therapeutic Solutions International, Inc.
November 14, 2022
Page 2
2.We note your statement on the cover page that the selling stockholders may offer the
shares of your common stock for resale in the over-the-counter market, in isolated
transactions, or in a combination of such methods of sale, and that the selling stockholders
will sell their shares at prevailing market prices or privately negotiated prices. We also
note the disclosure on page 4 and on the back cover that the offering price will be at a
20% discount to the market price. Finally, we note your statement on page 4: "We may
offer these securities in amounts, at prices and on terms determined at the time of offering.
The securities may be sold directly to you, through agents, or through underwriters and
dealers." Please revise to address these inconsistencies or clarify.
Prospectus Summary
The Offering, page 4
3.We note that Section 1(u) of the Purchase Agreement defines "Purchase Price" as "80% of
the lowest trading price of the Common Stock during the Valuation Period." We also note
that following such time that the Company's common stock is listed on a National
Exchange, the purchase price will be "90% of the lowest VWAP during the Valuation
Period, subject to a floor of $[   ] . . ." Please clearly disclose here how you will determine
the full discount price at which GHS Investments, LLC will receive the shares.
4.Please revise to disclose the material terms of the agreement with GHS Investments, LLC,
including the material conditions under which the company may access the funds
available under it and the term of the agreement (we note you refer to the Purchase
Agreement with GHS Investments, LLC as the "PA" and on page 48 say that a CSPA
(undefined) terminates on September 19, 2024). Please additionally disclose the material
market activities of GHS Investments, LLC, including any short selling of the company’s
securities or other hedging activities that GHS Investments, LLC may or has engaged in,
including prior to entering into the agreement and prior to the receipt of any shares
pursuant to the terms of the agreement, how it intends to distribute the securities it owns
or will acquire, and how the provisions of Regulation M may prohibit it and any other
distribution participants that are participating in the distribution of the company’s
securities from (i) engaging in market making activities (e.g., placing bids or making
purchases to stabilize the price of the common stock) while the equity line is in effect and
(ii) purchasing shares in the open market while the equity line is in effect.

 FirstName LastNameTimothy G. Dixon
 Comapany NameTherapeutic Solutions International, Inc.
 November 14, 2022 Page 3
 FirstName LastNameTimothy G. Dixon
Therapeutic Solutions International, Inc.
November 14, 2022
Page 3
Risk Factors, page 16
5.Please disclose the material risks of an investment in the company and in the offering,
including the dilutive effect of the formula or pricing mechanism on the company’s share
price, the possibility that the company may not have access to the full amount available to
it under the equity line and how any sales activities after announcement of a put including
short selling may negatively affect the company’s share price. Also consider the
applicability of the following risk factor on page 19: "This Offering is being placed on a
“best efforts” basis and we may not raise the entire $10,000,000" relating to an offering
of Restricted Shares and Units.
Selling Stockholders, page 43
6.Please revise to provide the information required by Item 507 of Regulation S-K. Refer to
Item 7 of Form S-1.
General
7.You disclose that you are registering the resale of an indeterminate number of shares of
your common stock that will be sold to GHS Investments, LLC under a Purchase
Agreement dated September 19, 2022. Per the securities Purchase Agreement, you may
sell up to $10,000,000 shares of common stock over the duration of the agreement. Please
note that you must disclose the number of common stock shares being registered on this
registration statement. Please revise the prospectus cover page, offering summary and
selling stockholder table to disclose the specific number of shares being registered under
the equity line agreement. Refer to Securities Act Sections Compliance and Disclosure
Interpretations Questions 139.13 and Item 501(b)(2) of Regulation S-K.
8.We note that it appears you may have elected to incorporate information by reference
pursuant to General Instruction VII. If you are intending to incorporate by reference
please provide us with an analysis as to your eligibility to incorporate by reference,
specifically as it relates to General Instruction VII(D)(1)(c). In this respect, we note your
statement on page 21: "Our common stock is considered to be penny stock under rules
promulgated by the Securities and Exchange Commission (the “SEC”)." If you are not
intending to incorporate by reference, please remove all references in the registration
statement to incorporating by reference and ensure all required information is included in
the registration statement. As an example, provide the information required by Item 303 of
Regulation S-K (Management's discussion and analysis of financial condition and results
of operation). We also note that filing your 10-K as Exhibit 13.2 does not satisfy any of
these requirements.
9.Please refile your exhibits in the proper text-searchable format. Please refer to
Item 301 of Regulation S-T. Please also revise to provide the information required by Item
16(a) of Form S-1.

 FirstName LastNameTimothy G. Dixon
 Comapany NameTherapeutic Solutions International, Inc.
 November 14, 2022 Page 4
 FirstName LastName
Timothy G. Dixon
Therapeutic Solutions International, Inc.
November 14, 2022
Page 4

            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.
            You may contact Jordan Nimitz at 202-551-5831 or Margaret Schwartz at  202-551-7153
with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Hugh Kelso, Esq.