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CORRESP
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American
Picture House Corporation

555
Madison Avenue 5FL New York, NY 10022

October
19, 2023

    Re:
    American
    Picture House Corp

    Amendment
No. 3 to Registration Statement on Form 10-12G

    Filed October 13, 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 18, 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:

Amendment
No. 2 to Registration Statement on Form 10-12G

Our
Chief Executive Officer and Chairman of the Board of Directors holds a significant

percentage of our outstanding voting securities, page
13

1. Please
                                            revise to quantify (by percentage) the voting power of Mr. MacGregor due to his ownership
                                            of common and Series A preferred stock. In this regard, we note that the percentage appears
                                            to be substantial in comparison to the voting power which will be held by other stockholders.
                                            Please also revise the Corporate History section on page 7 to disclose and quantify Mr. MacGregor’s
                                            ownership position (common and preferred) and voting power in the company.

Response:
Voting percentage has been included to both the Corporate History section on page 7 as well as disclosure on page 13.

Executive
Compensation, page 32

2. We
                                            note your response to comment 4 and reissue our comment in part. To the extent no compensation
                                            was paid to directors in 2022, so state. Alternatively, please include the disclosure required
                                            by Item 402(r) of Regulation S-K.

Response:
As requested we have added language to page 32 stating that no Directors were paid in excess of $100,000 during 2022.

Bannor
Michael MacGregor

American Picture House Corp

October 19, 2023

Page
2

Note
2 - Summary of Significant Accounting Policies Assigned

Rights
to the Feature Film, Buffaloed, page 63

3. The
                                            disclosure you provided in response to prior comment 9 appears to indicate that you acquired
                                            a receivable due from the CAMA in the amount of $249,924. Please tell us your basis in GAAP
                                            for recognizing this amount as revenue during the year ended December 31, 2022.

 Response:
                                            We have revised page 63 to the accounting at the date the Bold Crayon assets were acquired
                                            in November and to clarify that the revenue and receivable were subsequently recorded in
                                            December as a Type 2 subsequent event.

Note
7 - Equity Preferred

Stock, page 67

4. We
                                            read your response to prior comment 12. Please disclose the amount of the liquidation preference
                                            in the filing.

Response:
Form 10 has been amended to state that the Series A preferred stock has a liquidation preference equal to $12.02 per Series
A preferred share.

Sincerely,

American
Picture House

    By:

    /s/
    Bannor Michael MacGregor

    Name:

    Bannor
    Michael MacGregor

    Title:

    Chief
    Executive Officer