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NEWLAN LAW FIRM, PLLC

2201 Long Prairie Road, Suite 107-762

Flower Mound, Texas 75022

February 21, 2023

Scott Anderegg

Office of Trade & Services

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:       InnerScope
Hearing Technologies, Inc.

Offering Statement on Form 1-A

Filed January 26, 2023

File No. 024-12138

Dear Mr. Anderegg:

This is in response to the letter
of comment of the Staff dated February 15, 2023, relating to the captioned Offering Statement on Form 1-A of InnerScope Hearing Technologies,
Inc. (the “Company”). The comment of the Staff is addressed below:

Offering Statement on Form 1-A filed January
26, 2023

General

 1. You have checked the box indicating you meet the criteria for
                                                                                                            eligibility for the use of Form 1-A, including the criteria specified in Rule 251(b)(7) under the Securities Act. In this regard, we
                                                                                                            note that you filed Forms 8-K during 2022, filed a Form 10-K for the fiscal year ended December 31, 2020 and a Form 10-Q for the
                                                                                                            fiscal period ended March 31, 2020 in late 2022/early 2023, and have not filed any other periodic reports since your Form 10-Q for
                                                                                                            the period ended September 30, 2019. Please provide us with an analysis of your current reporting status and the nature of your
                                                                                                            filing obligations, so that we may further consider your eligibility under Rule 251(b)(7).

The Company filed a Form 15 with the Commission
on March 2, 2021. It appears that the Company’s recent filings, that is, those made after March 2, 2021 (the “Recent SEC Filings”),
on the Commission’s EDGAR system have caused a measure of confusion.

Since March 2, 2021, the Company has filed
the following periodic reports on the Commission’s EDGAR system, as a voluntary filer:

Periodic Reports Filed via the Commission’s
EDGAR System (in the order filed)

    Filing

    Date

    Report Title

    Period

    End Date

    02/21/2023
    Quarterly Report on Form 10-Q
    09/30/2020

    02/17/2023
    Quarterly Report on Form 10-Q
    06/30/2020

    01/26/2023
    Quarterly Report on Form 10-Q
    03/31/2020

    09/14/2022
    Annual Report on Form 10-K
    12/31/2020

    08/29/2022
    Current Report on Form 8-K
    08/18/2022

    08/16/2022
    Current Report on Form 8-K
    08/11/2022

    06/06/2022
    Current Report on Form 8-K
    04/28/2022

    05/31/2022
    Current Report on Form 8-K
    04/28/2022

    02/03/2022
    Current Report on Form 8-K
    01/31/2022

    01/21/2022
    Current Report on Form 8-K
    12/20/2021

    03/02/2021
    Form 15-12G
    03/02/2021

In general, the Recent SEC Filings
were made by the Company for two separate, though congruent, primary reasons. With respect to the Current Reports on Form 8-K
included in the Recent SEC Filings, the Company’s management considered their filing to be a prudent additional method of
disclosure, at the time. With respect to the Quarterly Reports on Form 10-Q and the Annual Report on Form 10-K included in the
Recent SEC Filings, such filings were made by the Company in accordance with advice received from its consultants, in light of its
having filed a Form 15.

Since the March 2, 2021, filing of its
Form 15 with the Commission, the Company has  filed periodic reports (the “ARS Reports”) listed below with OTC Markets
as an Alternative Reporting Standard Filer.

Periodic Reports Filed via the OTC Markets’
OTCIQ.com Platform (in the order filed)

    Filing

    Date

    Report Title

    Period

    End Date

    11/15/2022
    Quarterly Report - Financial and Disclosure Statements
    09/30/2022

    08/11/2022
    Quarterly Report - Financial and Disclosure Statements
    06/30/2022

    05/16/2022
    Quarterly Report - Financial and Disclosure Statements
    03/31/2022

    04/29/2022
    Annual Report - Amended Annual Report - Financial and Disclosure Statements
    12/31/2021

    04/07/2022
    Annual Report - Amended Annual Report - Financial and Disclosure Statements
    12/31/2021

    04/01/2022
    Annual Report - Financial and Disclosure Statements
    12/31/2021

    11/20/2021
    Quarterly Report - Financial and Disclosure Statements
    09/30/2021

    11/15/2021
    Notification of Late Filing
    09/30/2021

    08/14/2021
    Quarterly Report - Financial and Disclosure Statements
    06/30/2021

    07/16/2021
    Annual Report - Amended Financial Statements
    12/31/2019

    07/16/2021
    Quarterly Report - Amended Financial Reports
    03/31/2021

    07/16/2021
    Annual Report - Amended Financial Reports
    12/31/2020

    06/30/2021
    Quarterly Report - Amended Financial and Disclosure Statements
    03/31/2021

    06/30/2021
    Annual Report - Amended Financial and Disclosure Statements
    12/31/2020

    06/30/2021
    Annual Report - Amended Financial and Disclosure Statements
    12/31/2019

    06/23/2021
    Annual Report - Amended Financial Statements
    12/31/2020

    06/21/2021
    Quarterly Report - Financial and Disclosure Statements
    03/31/2021

    06/16/2021
    Annual Report - Financial and Disclosure Statements
    12/31/2020

    06/09/2021
    Quarterly Report - Financial and Disclosure Statements
    09/30/2020

    06/07/2021
    Quarterly Report - Financial and Disclosure Statements
    06/30/2020

    06/01/2021
    Quarterly Report - Financial and Disclosure Statements
    03/31/2020

    05/27/2021
    Annual Report - Financial and Disclosure Statements
    12/31/2019

In considering the Company’s eligibility
with respect to Rule 251(b)(7), the following grid is offered for ease of analysis:

    Filed with OTC Markets

    Before Filing Form 1-A

    Filed with SEC

    After Filing Form 15

    2022

    1Q-Q3

    1Q-Q2

    1Q-Q1

    ●

    ●

    ●

    2021

    10-K

    1Q-Q3

    1Q-Q2

    1Q-Q1

    ●

    ●

    ●

    ●

    2020

    10-K

    1Q-Q3

    1Q-Q2

    1Q-Q1

    ●

    ●

    ●

    ●

    ●

    ●

    ●

    ●

The Company was not required to file periodic
reports after March 2, 2021, yet the Company endeavored to file missing periodic reports with the Commission after its filing of the Form
15. The Company has filed all required periodic reports OTC Markets, in accordance with its guidelines, for the nine months ended September
30, 2022, and the fiscal years ended December 31, 2021 and 2020, and, thus, has complied with the filing requirements of Rule 251(b)(7).

______________________________

Please feel free to contact the
undersigned at (940) 367-6154, should you have any questions regarding any of the Company’s responses.

We believe the Company’s
Offering Statement is now in order for qualification.

Thank you for your attention in
this matter.

Sincerely,

NEWLAN LAW FIRM, PLLC

By: /s/ Eric Newlan

Eric Newlan

Managing Member

cc: InnerScope Hearing Technologies, Inc.