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January 27, 2023
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.
Amendment No. 2 to Registration Statement on Form S-1
Filed January 18, 2023
File No. 333-268070
Dear Timothy G. Dixon:
            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 December 19, 2022 letter.
Amendment No. 2 to Form S-1 filed January 18, 2022
Risk Factors, page 20
1.We note your revisions in response to our prior comment 2. We note that you are
registering up to 555,000,000 shares and that the purchase price under the equity financing
agreement is defined based on the trading price of your common stock. Given this, please
expand your risk factor titled “We may not have access to the full amount under the
Financing Agreement" to discuss the impact of the trading price per share on your ability
to access the full amount available under the equity financing agreement pursuant to this
registration statement, or advise. We note that at your current share price, 555,000,000
shares have a value between $3 and $4 million.

 FirstName LastNameTimothy G. Dixon
 Comapany NameTherapeutic Solutions International, Inc.
 January 27, 2023 Page 2
 FirstName LastName
Timothy G. Dixon
Therapeutic Solutions International, Inc.
January 27, 2023
Page 2
Executive Compensation, page 46
2.Please update your compensation disclosure for your recently completed fiscal year ended
December 31, 2022. For guidance, see Item 402 of Regulation S-K and
Question 117.05 of Regulation S-K Compliance and Disclosure Interpretations.
General
3.We note your revisions in response to our prior comment 6 and reissue in part. Your
prospectus still contains some references to incorporating by reference. Please revise the
below statements to remove the references to incorporating by reference Exchange Act
filings:

•on the Cover Page, "See “Risk Factors” beginning on page 20 and the risk factors in
our most recent Annual Report on Form 10-K, as well as in any other recently filed
quarterly or current reports and, if any, in the relevant prospectus supplement. We
urge you to carefully read this Prospectus, its exhibits, together with the documents
we are entitled to incorporate by reference, if any, describing the terms of these
securities before investing"; and
•on page F-15, it states that "The following discussion and analysis should be read in
conjunction with the accompanying financial statements and related notes, as well as
the Financial Statements and related notes in our Annual Report on Form 10-K for
the fiscal year ended December 31, 2021 and the risk factors discussed therein filed
with the SEC" and under Item 1A. Risk Factors, that "No material changes to risk
factors have occurred as previously disclosed in Item 1A of our Annual Report on
Form 10-K for the year ended December 31, 2021, which was filed with the SEC on
March 31, 2022."

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