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Altamira
Therapeutics Ltd.

Clarendon
House

2
Church Street

Hamilton
HM 11

Bermuda

February
28, 2023

Division
of Corporation Finance

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

    Attention:
    Lauren Hamill

    Joe McCann

Re: Altamira
                                            Therapeutics Ltd.

Registration
Statement on Form F-1

Filed
February 16, 2023

File
No. 333-269823

Dear
Ladies and Gentlemen:

This
letter is submitted by Altamira Therapeutics Ltd. (the “Company”) in connection with the Staff’s comment letter dated
February 24, 2023.

The
Staff’s comments have been retyped below in italics, and are followed by our responses:

General

1. SEC
                                            Comment: We note statements in numerous places throughout the registration statement stating
                                            or suggesting that your OligoPhore and SemaPhore peptide polyplex platform technology is
                                            “safe and effective.” By way of example only, please see the first graphic preceding
                                            the Table of Contents and pages 1, 11, 57, and 79. Similarly, your discussions of various
                                            clinical trials include statements that your product candidates are “safe and well tolerated”
                                            or have a “favorable safety profile,” such as on pages 55-57 and 84, 88, and 89.
                                            Please remove all statements throughout your registration statement that state or imply your
                                            conclusions regarding the safety or efficacy of your product candidates and technologies,
                                            as these determinations are solely within the authority of the FDA and comparable regulatory
                                            bodies. With respect to safety, we will not object to statements that your product candidates
                                            are well-tolerated, if true, or that no serious adverse events deemed to be study related
                                            were reported. You may also present a balanced summary of objective pre-clinical and clinical
                                            data, including whether clinical trials trial met primary and secondary endpoints, without
                                            including your conclusions related to efficacy.

Company
Response: The Company respectfully acknowledges the Staff’s comment and has made changes accordingly to the abovementioned
Registration Statement (the “Registration Statement”) on pages 1, 11, 55-57, 79, 84, 85, 86, 88 and 89 and through the removal
of the graphics preceding the Table of Contents.

February 28, 2023

Page 2

2. SEC
                                            Comment: With reference to the first page of graphics, please revise these graphics to adhere
                                            to plain English principles or remove them. In this regard, we note that these graphics include
                                            scientific and technical information without context and as such the content is likely to
                                            be unfamiliar to the average investor. Refer to Question 101.02 of our Securities Act Forms
                                            Compliance and Disclosure Interpretations for guidance.

Company
Response: The Company respectfully acknowledges the Staff’s comment and has removed the graphics preceding the Table of Contents.

3. SEC
                                            Comment: The pipeline table should graphically demonstrate the current status of your product
                                            candidates as well as indicate the material stages you will need to complete prior to regulatory
                                            approval and commercialization. In this regard:

●
We note you have included five columns that all appear to relate to pre-clinical development, which could inappropriately create the
impression of further candidate progress. The narrative discussion of your programs is a more appropriate place to make distinctions
regarding different segments within a particular development phase. Please revise to combine such columns, and note that we will not
object to pre-clinical stage columns of equal width labeled as “Discovery” and/or
“IND-enabling.”

●
Also, please revise to add separate columns of equal width for each of Phase 1, Phase 2, and Phase 3 clinical
testing.

Company
Response: The Company respectfully acknowledges the Staff’s comment and has removed the graphics preceding the Table of Contents.

****

All
disclosure changes in response to the staff’s comments will be addressed in future fillings made pursuant to the Securities Act
of 1933 and/or the Securities Exchange Act of 1934.

We
believe that this letter fully responds to your questions and/or comments. However, if you have any further questions or comments regarding
the foregoing, please feel free to contact the undersigned at 441-295-5950, or our counsel, Alexander Dinur of Lowenstein Sandler, LLP,
at 973-422-6732.

    Very truly yours,

    ALTAMIRA THERAPEUTICS LTD.

    By:
    /s/ Thomas Meyer

    Name:
    Thomas Meyer

    Title:
    Chief Executive Officer

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