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October 3, 2023
Bannor Michael MacGregor
Chief Executive Officer
American Picture House Corp
555 Madison Avenue 5FL
New York, NY 10022
Re:American Picture House Corp
Amendment No. 1 to Registration Statement on Form 10-12G
Filed September 22, 2023
File No. 000-56586
Dear Bannor Michael MacGregor:
            We have reviewed your filing and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response and any amendment you may file in response to this letter,
we may have additional comments.
Amendment No. 1 to Registration Statement on Form 10-12G
Risk Factors
Risks Related to the Company's Common Shares, page 13
1.We reissue comment 5.  Revise to include a risk factor discussing the different authorized
classes of stock, including the nature of the disparate voting rights, number of votes per
share to which each class is entitled and the potential dilution to common stock holders
upon conversion of the Series A preferred stock.

 FirstName LastNameBannor Michael MacGregor
 Comapany NameAmerican Picture House Corp
 October 3, 2023 Page 2
 FirstName LastName
Bannor Michael MacGregor
American Picture House Corp
October 3, 2023
Page 2
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
Three Months Ended June 30, 2023 Compared to Three Months Ended June 30, 2022
General and Administrative Expenses, page 19
2.Please revise your discussion in MD&A to explain the circumstances that resulted in your
determination that the collection of $193,932 from a customer is uncertain or improbable,
consistent with your response to comment 7.
Board of Directors, page 31
3.We note your revised disclosure in response to comment 9 and reissue our comment.
Revise to specifically identify each director that is independent under the independence
standards applicable to you.  Refer to Item 407(a)(1) of Regulation S-K.  In this regard,
we note that you have only identified the independent directors on each committee, but
you have not clearly identified all independent directors on the board as a whole.
Executive Compensation, page 32
4.We note your revised disclosure in response to comment 10 and reissue our comment.
Revise to include the disclosure required by Item 402(m)-(r) of Regulation S-K for the
fiscal year ended December 31, 2022.   In this regard, it appears you have only described
the compensation payable in fiscal year 2023.  Also ensure that your disclosure includes
the tables and narrative disclosure required by Regulation S-K.  To the extent no
compensation was paid to directors or officers in 2022, so state.
Statement of Operations for the Six Months Ended June 30, 2023, page 44
5.We note that you restated your statements of operations in response to comment 15.
Please identify the financial statements as “restated” and provide the disclosures required
under ASC 250-10-50 with respect to the correction of an error, as applicable.
Report of Independent Registered Public Accounting Firm, page 55
6.We reissue comment 14 in part, since you continue to provide two audit reports on pages
42 and 55 of your filing.  Please remove one of these audit reports and ensure that the
audit report provided is properly dated. Also, in light of your restatement in response to
comment 15, please obtain an audit report that includes an explanatory paragraph stating
that the previously issued financial statements have been restated for the correction of a
error and makes reference to the disclosure of the correction of the error in the notes to the
financial statements. Refer to paragraphs 9-10 and 16-17 of AS 2820.

 FirstName LastNameBannor Michael MacGregor
 Comapany NameAmerican Picture House Corp
 October 3, 2023 Page 3
 FirstName LastName
Bannor Michael MacGregor
American Picture House Corp
October 3, 2023
Page 3
Notes to the Financial Statements for the Years Ending December 31, 2022 and 2021
Note 2 - Summary of Significant Accounting Policies, page 60
7.We note your response to comment 17 but are unable to locate the disclosures referenced
in your response. Please tell us where you provided your accounting policy for stock-
based compensation as previously requested in comment 17.
Produced and Licensed Content Costs, page 61
8.Please revise the disclosure you provided in response to comment 19 to identify the
caption in the income statement where the amortization of production costs is recorded.
Assigned Rights to the Feature Film, Buffaloed, page 64
9.Please revise the disclosures you provided in response to comment 18 to quantify the fair
value of the assets acquired and the consideration incurred under the arrangement.  To the
extent the consideration is contingent, also disclose if and how such consideration
is remeasured.
Revenues and Costs from Services and Products, page 64
10.The disclosure you provided in response to comment 22 appears to only describe your
revenue recognition policy for consulting services.  Please revise this disclosure to also
describe how you account for revenues from licensing and distribution of film and other
entertainment rights.
11.We reissue comment 23 as you did not appear to address it.  Where you state that “a
majority of the consulting services were performed by management and members of the
Board of Directors with no separate compensation due or payable to these individuals,”
describe if and how you measure and allocate their labor to the cost of revenues.
Note 6 - Equity, page 68
12.Please revise your disclosure to quantify the liquidation preference as previously
requested under comment 25.

 FirstName LastNameBannor Michael MacGregor
 Comapany NameAmerican Picture House Corp
 October 3, 2023 Page 4
 FirstName LastName
Bannor Michael MacGregor
American Picture House Corp
October 3, 2023
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.
            Please contact Keira Nakada at 202-551-3659 if you have questions regarding comments
on the financial statements and related matters. Please contact Taylor Beech at 202-551-4515 or
Jennifer Lopez Molina at 202-551-3792 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Gary L. Blum, Esq.