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American
Picture House Corporation

555
Madison Avenue 5FL New York, NY 10022

October
12, 2023

    Re:
    American
    Picture House Corp

    Amendment
    No. 1 to Registration Statement on Form 10-12G

    Filed
    September 22, 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 October 3, 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:

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.

    Response:
    We
                                            have added risk factors discussing the different authorized classes of stock, including language
                                            to state 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 on page 13.

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.

    Response:
    As
    requested, we have added language describing the determination as to why the collection of approximately $194,000 from the customer
    has been deemed improbable.

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.

    Response:
    Language
    identifying the Independent Directors has been added to page 31.

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.

  Response:
  Per Item
  402(m)-(r) of Regulation S-K for the fiscal year ended December 31, 2022, the compensation of the CEO has been included on page 32.
  As no other officer had compensation of over $100,000, the CEO is the only officer listed.

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.

  Response:
  We have
  updated the Statements of Operations (page 44 and 57). Additionally, we have included in note 2 (page 47 & 60) a restatement of
  previously issued financial statements.

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.

  Response:
  The audit
  report on page 42 was removed and an explanatory paragraph has been included as requested (page 55).

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.

  Response:
  We have
  added disclosures related to stock based compensation (pages 50 and 65) as requested.

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.

  Response:
  Disclosure has been revised as requested
  (page 63).

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.

  Response:
  Disclosure as to quantification of fair
  value of asset has been added (page 64).

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.

  Response:
  Revenue recognition policy has been
  included on page 64.

  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.

  Response:
  We revised
  the note to provide greater clarity regarding allocation of consulting services and have notated that in this case it has been deemed
  as immaterial.

Note
6 - Equity, page 68

  12.
  Please revise
  your disclosure to quantify the liquidation preference as previously requested under comment 25.

  Response:
  Language quantifying the liquidation
  preference has been included on page 68.

Sincerely,

American
Picture House

    By:

    /s/
    Bannor Michael MacGregor

    Name:

    Bannor
    Michael MacGregor

    Title:

    Chief
    Executive Officer