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October 19, 2022
Shuang Liu
Chief Executive Officer, President, and Director
Goldenwell Biotech, Inc.
2071 Midway Drive
Twinsburg, OH 44087
Re:Goldenwell Biotech, Inc.
Form 10-K for the Fiscal Year ended December 31, 2021
Filed April 1, 2022
Response Dated October 5, 2022
File No. 000-56275
Dear Shuang Liu:
            We have reviewed your October 5, 2022 response to our comment letter and have the
following comments.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
            Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
August 3, 2022 letter.
Form 10-K for the Fiscal Year ended December 31, 2021
Management's Discussion and Analysis
General, page 11
1.We note that you have proposed revisions to various disclosures that will appear in an
amendment to your annual report in response to prior comment one. Please further revise
your disclosures and financial statements to address the following additional points.

•We note that you deleted the reference to Gagfare Limited which was previously
identified as a wholly-owned subsidiary that is incorporated in Hong Kong, also party
to an agreement under which it would share 50% of earnings generated though
certain website and mobile application platforms.  Update your disclosure to explain

 FirstName LastNameShuang Liu
 Comapany NameGoldenwell Biotech, Inc.
 October 19, 2022 Page 2
 FirstName LastNameShuang Liu
Goldenwell Biotech, Inc.
October 19, 2022
Page 2
what became of this entity and to describe the status of the agreement and the nature
and extent of any business operations or plans, including any activities that would be
conducted in the People's Republic of China (PRC), Hong Kong or Macau.

•Revise the amounts reported as Total Assets and Stockholders' Equity in the
Financial Summary on page 4 to agree with the corresponding amounts on page F-2.

•Reposition the “Other income and expenses” group of line items on page F-3 to
precede “Net loss before income taxes” and correct the measure of “Net loss before
income taxes” reported on pages 11 and F-3.

•Expand the disclosure under Plan of Operation on page 11 to describe the
circumstances under which you generated $15,967 in revenues from sales of your
nutraceutical and dietary supplements, to clarify how this activity reconciles with
disclosure under Going Concern on page 11, which states that no revenues are
anticipated until you complete a financing and implement your business plan.
Management's Discussion and Analysis
Liquidity and Capital Resources, page 12
2.We note that you have added disclosure in the last paragraph on page 12, in response to
prior comment two, of material hurdles to complete before you can sell your products
commercially, and estimates of funding and the amount of time required to complete these
activities.  Please revise the accompanying disclosure, clarifying that you do not have any
financing arranged and cannot provide investors with any assurance of being able to fund
your exploration activities, to either correct this reference to exploration activities, or to
explain how these activities reconcile with those described as the material hurdles.
Report of Independent Registered Public Accounting Firm, page F-1
3.We note that in response to prior comment three, you modified your Table of Contents on
page 15 to include a reference to an audit report of Michael Gillespie & Associates, and
revised the Exhibit Index on page 25 to list the firms consent.

We understand that you will be filing the audit report and consent of this prior auditor
along with the audit report of your present auditor in an amendment to your annual report.

Please confirm that you have made appropriate arrangements with the prior auditor for a
reissuance of their opinion in response to this comment.

 FirstName LastNameShuang Liu
 Comapany NameGoldenwell Biotech, Inc.
 October 19, 2022 Page 3
 FirstName LastName
Shuang Liu
Goldenwell Biotech, Inc.
October 19, 2022
Page 3
            You may contact Joseph Klinko at (202) 551-3824 or Lily Dang at (202) 551-3867 if
you have questions regarding comments on the financial statements and related matters.
Please contact Karl Hiller, Branch Chief at (202) 551-3686 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation