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 August 14, 2025

Bradley Burnam
Chief Executive Officer
Global Health Solutions, Inc
250 N. Westlake Blvd.
Westlake Village, CA 91362

 Re: Global Health Solutions, Inc
 Amendment No. 1 to Draft Registration Statement on Form S-1
 Submitted July 30, 2025
 CIK No. 0002023016
Dear Bradley Burnam:

 We have reviewed your amended draft registration statement and have the
following
comments.

 Please respond to this letter by providing the requested information
and either
submitting an amended draft registration statement or publicly filing your
registration
statement and non-public draft submissions on EDGAR. If you do not believe a
comment
applies to your facts and circumstances or do not believe an amendment is
appropriate, please
tell us why in your response.

 After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our July 17, 2025 letter.

Amendment No. 1 to Draft Registration Statement on Form S-1
Overview, page 2

1. We note that the first two paragraphs both highlight three FDA medical
device
 clearances and their extensive use in humans. To the extent that you
highlight these
 clearances and this history in the first two paragraphs, please revise
to explain that
 these products are not presently on the market and/or that you are not
currently
 generating revenues from these devices.
 August 14, 2025
Page 2
Core Products and Programs, page 4

2. We note your revisions in response to prior comment 7. Please further
revise
 disclosures concerning the first three medical devices to disclose the
year of FDA
 clearance and to include the drug/program names that you utilize on
pages 10-11 (e.g.,
 XEAL (K183681)). Disclose that the fourth medical device presented is
out-licensed
 to MiMedx. For the GX-03 eczema drug candidate, please revise to
indicate that the
 referenced human trials are Phase 2-equivalent.
GX-03 Development Roadmap: Eczema & Onychomycosis, page 5

3. We note your response to prior comment 9. As presented, the graphic
appears to
 indicate that the Pivotal Phase 3 trials will start and end in Q4 2026.
Please revise or
 advise. Also, revise to remove the NDA Submissions row given its
speculative nature.
Immunomodulatory Activity Without the Cost and Risks of Biologics, page 7

4. Please revise to explain the term cytokine modulation and clarify
whether this was
 demonstrated in pre-clinical work or in humans. Also, revise the
Business section to
 present support for this claim or tell us where such support is
presented.
Clinical Products, page 10

5. With reference to prior comment 16, please revise your disclosure to
identify the two
 FDA-cleared products that you have packaged for out-licensing.
6. We note your disclosure on page 8 that you have historically licensed
cleared medical
 device technologies including wound dressings and antimicrobial
platforms to
 commercial partners. As applicable, please revise the disclosures on
pages 10-11 to
 indicate whether any of the three FDA-cleared medical devices were
out-licensed in
 the past. If so, please revise the Business section, or elsewhere as
applicable, to
 identify each licensee and the date of each commercial partnership.
If we are unable to obtain, maintain and enforce patent protection for our
current products...,
page 35

7. We note your response to prior comment 25. Based on the inventions at
issue, please
 revise the disclosure on page 37 to indicate whether any future
licensing demands
 likely would pertain to one or all of your product candidates.
Liquidity and Capital Resources, page 63

8. With reference to your Development Roadmap on page 5, please revise your
Liquidity
 and Capital Resources discussion and/or Business section disclosures to
indicate how
 much funding you will require over the next twelve months as well as the
 amount needed to complete your planned pivotal Phase 3 trials for eczema
and
 onychomycosis. Also explain your material funding needs in 2025 and 2026
for any
 other products candidates that you may be developing during this
timeframe.
 August 14, 2025
Page 3
Business, page 69

9. We note your revisions in response to prior comment 3. Please revise the
Business
 section, where appropriate, to present a detailed summary of the "Diaper
Dermatitis
 and Treatment of Phytophotodermatitis with Topical Antimicrobial: A
Case Report
 case studies. Identify the providers and indicate when the case studies
were
 performed. Disclose whether the providers are or were affiliated with
you and whether
 you provided compensation for their efforts. Provide similar disclosures
with respect
 to the A Novel Approach to Polymicrobial Nail Infection case study
and include the
 patient results so it is clear how these results suggested efficacy
ranging from 70-
 85%.
Share Purchase Agreement, page 93

10. Your disclosure on page 94 indicates that you have contractual
obligations under the
 agreement to file a resale registration statement concurrently with the
filing of the
 registration statement covering this Direct Listing. With reference to
Compliance
 Disclosure Interpretations, Securities Act Sections, Q. 139.13, please
note that you
 would not be eligible to file a registration statement covering the
equity line
 transaction until such time as there is an existing market for the
securities.
 Accordingly, please advise us concerning your plans for registration of
the equity line
 arrangement.
Sale Price History of Our Capital Stock, page 111

11. We note your revised disclosure in response to prior comment 30. Please
revise to
 provide the disclosure specified in Regulation S-K, Item 201(a)(3) or
explain why it is
 not applicable.
Notes to Consolidated Financial Statements
9. Licensing Agreements, page F-21

12. We note your response to prior comment 31. Please revise your disclosure
to clarify
 the specific development and commercialization performance obligations.
General

13. Given Clear Street LLC s dual role as your financial advisor and a
Registered
 Stockholder and the financial advisor s role under Nasdaq direct
listing rules, please
 consider whether it is necessary to include a discussion of any material
risk factors
 relating to potential conflicts of interest.
14. We note the disclosure on your cover page that the Registered
Stockholders will
 [not] be involved in Nasdaq's price-setting mechanism, including any
decision to
 delay or proceed with trading, nor will . . . they control or influence
the Advisor in
 carrying out its role as a financial adviser. Please revise this and
any other similar
 statements for consistency given Clear Street LLC s current dual role
as your financial
 advisor and a Registered Stockholder.
15. Please confirm that Clear Street LLC will not serve as the issuer s
valuation agent for
 purposes of the Nasdaq direct listing rules.
 August 14, 2025
Page 4

 Please contact Vanessa Robertson at 202-551-3649 or Sasha Parikh at
202-551-3627
if you have questions regarding comments on the financial statements and
related
matters. Please contact Lauren Sprague Hamill at 303-844-1008 or Joe McCann at
202-551-
6262 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
cc: Stephen A. Byeff
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