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American
Picture House Corporation

555
Madison Avenue 5FL New York, NY 10022

September
22, 2023

    Re:
    American
    Picture House Corporation

    Registration
    Statement on Form 10-12G, Filed

    August
    15, 2023

    File
    No. 000-56586

To
Whom it may Concern:

American
Picture House Corporation (the “Company” or “APH”) is in receipt of your comment letter dated September 11, 2023
regarding the above referenced filing. As requested in your letter, we have provided responses to the questions raised by the staff.
For your convenience, the matters are listed below, followed by the Company’s responses:

Business

Business
Overview, page 3

1. We
                                            note that the only revenues you have generated during the financial periods presented are
                                            consulting revenues. Please revise this section to include a description of the consulting
                                            services you offer.

 Response: To
                                            address this issue we have added language to state that the Company had previously been engaged
                                            as a consultant to entertainment industry clients. The nature of the consulting services
                                            were also described. The Company is no longer offering consulting services and this has been
                                            reflected in the revision.

2. We
                                            note your disclosure that the Company’s management, board of directors and advisors
                                            have relationships with major studios, streaming services leading talent agencies, and proven
                                            foreign sales companies. Please provide more detail regarding these relationships, including
                                            whether the Company has entered into any related agreements.

    Response:
    We
    have clarified the expertise of our officers and board members and specified why we believe their past experience will be helpful
    to the Company moving forward. Additionally, we have stated that none of the relationships of our Officers and Directors has yet
    to result in any agreement being signed to date.

3. Please
                                            clarify how the Company’s management and advisors will use certain IP assets to “limit
                                            risk” and “guarantee greater profitability.”

 Response: We
                                            have added descriptive language describing how various elements and additional factors can
                                            enhance a film’s or show’s IP and how such enhancement can be utilized to create
                                            a strong package that can offer financial benefits to the Company, thereby reducing risk
                                            and providing a greater chance of achieving positive financial results.

Intellectual
Properties, page 5

4. We
                                            note your disclosure that you own a portfolio of intellectual properties and option rights
                                            for several screenplays, a portion of the beneficial ownership to the feature film Buffaloed,
                                            and that you are currently in production of Devil’s Half Acre. Please revise
                                            to clarify the status of production for Devil’s Half Acre and the other screenplays
                                            for which you have ownership rights, and explain the nature of your beneficial ownership
                                            rights.

 Response: Descriptive
                                            language has been added to clarify the Company’s IP as well as the ownership rights
                                            of Devils Half Acre and Buffaloed.

Risks
Related to the Company’s Common Shares, page 13

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.

 Response: This
                                            risk factor has been included as requested.

Risk
Factors

Our
largest shareholder, officer, and director, Bannor Michael MacGregor..., page 15

6. It
                                            appears that you have only included the heading for this risk factor. Please revise to include
                                            the body of the risk factor, including a reference to the Series A preferred stock owned
                                            by Mr. MacGregor and his respective voting rights.

    Response:
    This
    risk factor has been revised as requested.

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, page 19

7. Please
                                            describe the change in the circumstances since your revenue recognition that resulted in
                                            your determination that the collection of $193,932 from a customer is uncertain or improbable.

 Response: The
                                            customer that owes APH $193,932 has had their Managing Director resign and has ceased operations.
                                            Consequently, APH views the recuperation of this accounts receivable as highly improbable.

Security
Ownership of Certain Beneficial Owners and Management, page 27

8. Revise
                                            the line item for Mr. MacGregor to also include the shares held by the Noah Morgan Private
                                            Family Trust.

    Response:
    The
    Security Ownership of Certain Beneficial Owners and Management table has been revised to combine Bannor MacGregor and Noah Morgan
    Private Family Trust.

Board
of Directors, page 31

9. 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.

    Response:
    Page
    31 has been revised to indicate the names of the two independent directors of the Audit Committee.

Executive
Compensation, page 32

10. Revise
                                            to include the disclosure required by Item 402(m)-(r) of Regulation S-K. In this regard,
                                            it appears that Mr. MacGregor is entitled to compensation pursuant to his Consulting Agreement
                                            filed as Exhibit 10.1 to this registration statement. Revise to describe such agreement in
                                            your filing and clarify whether your other executive officers have entered into consulting
                                            agreements with the company. If so, file such agreements as exhibits to the registration
                                            statement and describe the agreements in your filing.

  Response:
  A disclosure of executive
  compensation regarding our CEO Bannor Michael MacGregor has been added to Item 6.

Certain
Relationships and Related Transactions, and Director Independence, page 32

11. Revise
                                            to include the disclosure required by Item 404 of Regulation S-K. In this regard, we note
                                            you have several references to related party transactions throughout your filing, but you
                                            have not included any disclosure under this item.

  Response:
  Disclosure of all Certain
  Relationships and Related Transactions have been added to item 7 of the Form 10.

Market
Price of Dividends on the Registrant’s Common Equity and Related Shareholder Matters

 Market Information, page
33

12. Disclose
                                            that any over-the-counter market quotations reflect inter-dealer prices, without retail mark-up,
                                            mark-down or commission, and may not necessarily represent actual transactions. Refer to
                                            Item 201(a)(ii) of Regulation S-K.

  Response:
  Disclosure has been added
  as requested to reflect that any over-the-counter market quotations reflect inter-dealer prices, without retail mark-up, mark-down
  or commission, and may not necessarily represent actual transactions.

Equity
Compensation Plan Information, page 34

13. We
                                            note your disclosure that the company does not currently have an equity compensation plan
                                            in place, yet you have filed an equity compensation plan as Exhibit 10.4. Please revise for
                                            consistency and include a description of the material terms of the plan in the filing.

  Response:
  The Equity Compensation
  Plan has been revised to include clarification on plan administration, maximum number of shares available under the plan. Additionally,
  the termination of options due to expiration termination forfeiture and un-exercised shares was defined as well as 3,810,221 shares
  being approved but not yet issued.

Report
of Independent Registered Public Accounting Firm, page 40

14. We
                                            note that you have included two different audit reports of the independent registered public
                                            accounting firm in your registration statement on your financial statements for the year
                                            ended December 31, 2022. Please revise to include only the report that covers both audited
                                            periods presented in the financial statements and is dated August 15, 2023.

  Response:
  We have revised as requested
  by only providing the audit report dated August 15.

Statement
of Operations for the Six Months Ended June 30, 2023, page 42

15. Please
                                            tell us why you do not include bad debt expense as a part of your operating expenses. Cite
                                            the accounting guidance you relied upon for your classification.

  Response:
  We concur that bad debt
  expense should be part of operating expenses and we have amended the Form 10 and financials to reflect these changes.

Notes
to the Financial Statements for the Three and Six Months Ending June 30, 2023 and 2022

Note 8 - Related Party Transactions, page 51

16. You
                                            state here that you had accrued consulting fees of $5,000 as of December 31, 2022 while stating
                                            that you had accrued $105,000 on page 64. Please reconcile and resolve this inconsistency.

  Response:
  We agree that the correct
  amount on page 51 should be $105,000. We have amended accordingly.

Notes
to the Financial Statements for the Years Ending December 31, 2022 and 2021

Note 2 - Summary of Significant Accounting Policies, page
58

17. Please
                                            disclose your accounting policy for stock-based compensation, which includes issuance of
                                            common stock for services, as well as the options to purchase common stock. In addition,
                                            provide the disclosures required under ASC 718-10-50, as applicable.

  Response:
  We have inserted language
  defining our accounting policy for equity based-compensation plans as well as stock based compensation, including recognition
  of compensation expense for all equity based payments to employees. The policy includes grants of share options, defining the fair
  value of share options.

Assigned
Rights to the Feature Film, Buffaloed, page 59

18. Please
                                            disclose the significant terms of the agreement under which you were assigned certain rights
                                            to the feature film, Buffaloed, including cost and future obligations. In this regard,
                                            you state on page 66 that you paid off a $130,000 debt obligation in connection with the
                                            revenue payment received for Buffaloed. In addition, tell us whether this debt obligation
                                            was reflected in your balance sheet at December 31, 2022 and where on the June 30, 2023 cash-flow
                                            statement the repayment is reflected. Furthermore, if the rights relating to Buffaloed
                                            were transferred to you from a related party at a cost below the fair value, provide
                                            us an analysis of whether the difference represents a capital contribution.

  Response:
  The significant terms
  of the agreement between Bold Crayon and the Company, including the nature of the assets, transaction price and timing of said agreement
  has been included in the revised Form 10.

  The debt obligation was
  recorded in accounts payable and accrued expenses on the balance sheet of YE 2022 financials. We have revised the financials and broken
  down the items for clarity.

  The rights relating to
  Buffaloed were obtained for fair market value.

Produced
and Licensed Content Costs, page 59

19. Describe
                                            the nature and types of production costs you capitalize and reference the accounting guidance
                                            which you rely upon in your accounting for the capitalization, amortization, and impairment
                                            of these assets. In addition, disclose the caption in the income statement where the amortization
                                            would be recorded. Refer to ASC 926-20-50- 4A.

  Response:
  We have included language
  defining our accounting processes for investment in film and television programs, licensed program rights and impairment assessment.
  Also, we have disclosed the caption in the income statement where the amortization would be recorded.

20. Please
                                            disclose the components of film costs (including released, completed and not released, in
                                            production, or in development or preproduction) separately for films predominantly monetized
                                            on their own and films predominantly monetized with other films and/or license agreements.
                                            Refer to ASC 926-20-50-2.

 Response: We
                                            have added language disclosing and clarifying costs associated with production, including
                                            development costs, direct costs and production overhead, which are capitalized. Additionally,
                                            we have delineated accounting processes for investment in film and television programs, licensed