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 September 11, 2025

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

 Re: Global Health Solutions, Inc
 Registration Statement on Form S-1
 Filed September 2, 2025
 File No. 333-289972
Dear Bradley Burnam:

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

 Please respond to this letter by amending your registration statement
and providing
the requested information. 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 any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our August 14,
2025 letter.

Registration Statement on Form S-1
Competitive Strengths, page 7

1. Please revise the text beneath the "Intellectual Property Protecting
Core Technology
 and Product Candidates" heading to briefly summarize your revised risk
factor
 disclosure on page 37 indicating that it is possible that a patent with
overlapping
 claims with respect to the Hexagen formula could issue to a third party
and to briefly
 discuss potential consequences. Please similarly revise the
"Intellectual Property"
 subsection of your Business section to discuss this possibility and to
disclose the type
 of patent that could be issued, as well as the subject matter covered by
the pending
 patent application. Also discuss the reason(s), if any, that the U.S.
Court of Appeals
 provided in support of its decision resulting in Mr. Selner's retention
of the patent
 application.
 September 11, 2025
Page 2

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Six Months ended June 30, 2025 Compared to Six Months ended June 30, 2024, page
65

2. Please revise your disclosure to break out research and development
expenses
 incurred in the periods presented between the clinical trial program
related to
 Hexagen s purported eczema effects and your vaccine candidate.
Sale Price History of Our Capital Stock, page 119

3. We note your response to prior comment 11. We further note that your
disclosure
 indicates that you have offered shares pursuant to Regulation A,
Regulation D and
 Regulation CF within the prior two fiscal years. Please revise to
disclose the
 transaction history of your common stock in fiscal 2023, fiscal 2024 and
applicable
 interim periods in fiscal 2025. In your revisions, please disclose the
number of shares
 sold and the applicable share price.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

 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 Alan Campbell at 202-551-4224 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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