SecProbe.io

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 celz_corresp.htm December 9, 2025 Via Edgar Ms. Jessica Dickerson Division of Corporation Finance Office of Life Sciences U.S. Securities and Exchange Commission Washington, D.C. 20549 Re: Creative Medical Technology Holdings, Inc. Registration Statement on Form S-3 Filed November 21, 2025 File No. 333-291713 Request for Acceleration Dear Ms. Dickerson: Pursuant to Rule 461 under the Securities Act of 1933, as amended, Creative Medical Technology Holdings, Inc. (the “Company”) hereby requests acceleration of the effective date of the above-referenced Registration Statement to 4:00 p.m. on Friday, December 12, 2025, or as soon thereafter as practicable. Please contact Zev M. Bomrind of Pachulski Stang Ziehl & Jones LLP, counsel to the Company, at (646) 483-5497, as soon as the registration statement has been declared effective, or if you have any other questions or concerns regarding this matter. Sincerely, /s/ Timothy Warbington Timothy Warbington Chief Executive Officer

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 celz_corresp.htm April 9, 2025 Via Edgar Mr. Tyler Howes Division of Corporation Finance Office of Life Sciences U.S. Securities and Exchange Commission Washington, D.C. 20549 Re: Creative Medical Technology Holdings, Inc. Registration Statement on Form S-3 Filed April 2, 2025 File No. 333-286346 Request for Acceleration Dear Mr. Howes: Pursuant to Rule 461 under the Securities Act of 1933, as amended, Creative Medical Technology Holdings, Inc. (the “Company”) hereby requests acceleration of the effective date of the above-referenced Registration Statement to 4:00 p.m. on Friday, April 11, 2025, or as soon thereafter as practicable. Please contact Zev M. Bomrind of Pachulski Stang Ziehl & Jones LLP, counsel to the Company, at (646) 483-5497, as soon as the registration statement has been declared effective, or if you have any other questions or concerns regarding this matter. Sincerely, /s/ Timothy Warbington Timothy Warbington Chief Executive Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 8, 2025

Timothy Warbington
Chief Executive Officer
Creative Medical Technology Holdings, Inc.
211 E Osborn Road
Phoenix, AZ 85012

 Re: Creative Medical Technology Holdings, Inc.
 Registration Statement on Form S-3
 Filed April 2, 2025
 File No. 333-286346
Dear Timothy Warbington:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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.

 Please contact Tyler Howes at 202-551-3370 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
cc: Zev M. Bomrind, Esq.
</TEXT>
</DOCUMENT>

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 November 15, 2024

 Via Edgar

 Mr. Joshua Gorsky

 Division of Corporation Finance

 Office of Life Sciences

 U.S. Securities and Exchange Commission

 Washington, D.C. 20549

   Re:

  Creative Medical Technology Holdings, Inc.

  Registration Statement on Form S-1

  Filed November 8, 2024

  File No. 333-283091

  Request for Acceleration

 Dear Mr. Gorsky:

 Pursuant to Rule 461 under the Securities Act of 1933, as amended, Creative Medical Technology Holdings, Inc. (the “Company”), hereby requests acceleration of the effective date of the above-referenced Registration Statement to 4:00 p.m. on Tuesday, November 19, 2024, or as soon thereafter as practicable.

 Please contact Zev M. Bomrind of Pachulski Stang Ziehl & Jones LLP, counsel to the Company, at (646) 483-5497, as soon as the registration statement has been declared effective, or if you have any other questions or concerns regarding this matter.

   Sincerely,

      /s/ Timothy Warbington

  Timothy Warbington

        Chief Executive Officer

November 14, 2024
Timothy Warbington
Chief Executive Officer
Creative Medical Technology Holdings, Inc.
211 E Osborn Road
Phoenix, Arizona 85012
Re:Creative Medical Technology Holdings, Inc.
Registration Statement on Form S-1
Filed November 8, 2024
File No. 333-283091
Dear Timothy Warbington:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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.
            Please contact Joshua Gorsky at 202-551-7836 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Zev M. Bomrind, Esq.

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celz_corresp.htmCreative Medical Technology Holdings, Inc.

 211 E Osborn Road

 Phoenix, Arizona 85012

 October 10, 2024

 Via Edgar

 Ms. Doris Stacey Gama

 Division of Corporation Finance

 Office of Life Sciences

 U.S. Securities and Exchange Commission

 Washington, D.C.  20549

   Re:

   Creative Medical Technology Holdings, Inc.

 Registration Statement on Form S-3

 Filed October 4, 2024

 File No. 333-282512

 Request for Acceleration

 Dear Ms. Gama:

 Pursuant to Rule 461 under the Securities Act of 1933, as amended, Creative Medical Technology Holdings, Inc. (the “Company”) hereby requests acceleration of the effective date of the above-referenced Registration Statement to 4:00 p.m. on Tuesday, October 15, 2024, or as soon thereafter as practicable.

 Please contact Zev M. Bomrind of Pachulski Stang Ziehl & Jones LLP, counsel to the Company, at (646) 483-5497, as soon as the registration statement has been declared effective, or if you have any other questions or concerns regarding this matter.

   Sincerely,

   /s/ Timothy Warbington

   Timothy Warbington

   Chief Executive Officer

October 10, 2024
Timothy Warbington
Chief Executive Officer
Creative Medical Technology Holdings, Inc.
211 E. Osborn Road
Phoenix, AZ 85012
Re:Creative Medical Technology Holdings, Inc.
Registration Statement on Form S-3
Filed October 4, 2024
File No. 333-282512
Dear Timothy Warbington:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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.
            Please contact Doris Stacey Gama at 202-551-3188 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Zev M. Bomrind, Esq.

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celz_corresp.htmCreative Medical Technology Holdings, Inc.

 211 E. Osborn Road

 Phoenix, Arizona 85012

 May 17, 2022

 Via Edgar

 Ms. Christine Westbrook

 Division of Corporation Finance

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C.  20549

   Re:

   Creative Medical Technology Holdings, Inc.

   Registration Statement on Form S-3

   Filed May 10, 2022

 File No. 333-264824

 Dear Ms. Westbrook:

 Pursuant to Rule 461 under the Securities Act of 1933, as amended, Creative Medical Technology Holdings, Inc. hereby requests acceleration of the effective date of the above-referenced Registration Statement to 5:00 p.m. on May 19, 2022, or as soon thereafter as is practicable.

 Please contact Zev M. Bomrind of Fox Rothschild LLP, counsel to the Company, at (212) 878-7951, as soon as the registration statement has been declared effective, or if you have any other questions or concerns regarding this matter.

   Sincerely,

   /s/ Timothy Warbington

   Timothy Warbington

   Chief Executive Officer

United States securities and exchange commission logo
May 16, 2022
Timothy Warbington
Chief Executive Officer
CREATIVE MEDICAL TECHNOLOGY HOLDINGS, INC.
211 E. Osborn Road
Phoenix, AZ 85012
Re:CREATIVE MEDICAL TECHNOLOGY HOLDINGS, INC.
Registration Statement on Form S-3
Filed May 10, 2022
File No. 333-264824
Dear Mr. Warbington:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Christine Westbrook at 202-551-5019 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Zev M. Bomrind, Esq.

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celz_corresp.htm

 101 Park Avenue
Suite 1700
New York, NY 10178

 Tel (212) 878-7900

 Fax (212) 692-0940

 www.foxrothschild.com

 December 2, 2021

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Life Sciences

 100 F Street, N.E.

 Washington, DC 20549

    Attention:

   Christine Westbrook

 Celeste Murphy

   Re:

   Creative Medical Technology Holdings, Inc.

 Amendment No. 2 to Registration Statement on Form S-1 Filed December 1, 2021

 File No. 333-259834

Ladies and Gentlemen:

 On behalf of our client, Creative Medical Technology Holdings, Inc. (the “Company”), we are responding to the comment of the staff (the “Staff”) of the Securities and Exchange Commission contained in its letter dated December 2, 2021 (the “Comment Letter”), relating to the above referenced Registration Statement on Form S-1 (the “Registration Statement”). In response to the comment set forth in the Comment Letter, the Company has revised the Registration Statement and is filing Amendment No. 3 thereto with this response letter. In this letter, we have recited the Staff’s comment in italicized, bold type, followed by Company’s response.

 U.S. Securities and Exchange Commission

 December 2, 2021
Page 2

 Cover Page

    1.

   Please disclose on the cover page that you do not intend to apply for listing of the Public Warrants or pre-funded warrants on any national securities exchange or trading system, as referenced on page 5.

 We have revised the cover page as requested.

 Very truly yours,

 /s/ Zev M. Bomrind

 Zev M. Bomrind

 cc: Timothy Warbington

United States securities and exchange commission logo
December 2, 2021
Timothy Warbington
Chief Executive Officer
Creative Medical Technology Holdings, Inc.
211 E. Osborn Road
Phoenix, AZ 85012
Re:Creative Medical Technology Holdings, Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed December 1, 2021
File No. 333-259834
Dear Mr. Warbington:
            We have reviewed your amended registration statement and have the following
comment.  In our comment, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our 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 the comment, we may have additional comments.
Amendment No. 2 to Form S-1 filed December 1, 2021
Cover page
1.Please disclose on the cover page that you do not intend to apply for listing of the Public
Warrants or pre-funded warrants on any national securities exchange or trading system, as
referenced on page 5.

 FirstName LastNameTimothy Warbington
 Comapany NameCreative Medical Technology Holdings, Inc.
 December 2, 2021 Page 2
 FirstName LastName
Timothy Warbington
Creative Medical Technology Holdings, Inc.
December 2, 2021
Page 2
            Please contact Christine Westbrook at 202-551-5019 or Celeste Murphy at 202-551-
3257 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Zev M. Bomrind, Esq.

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celz_corresp.htmRoth Capital Partners, LLC

 888 San Clemente Drive

 Newport Beach, CA 92660

 November 30, 2021

 Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

   Re:

   Creative Medical Technology Holdings, Inc. (the “Company”)

   Registration Statement on Form S-1 (File No. 333-259834)

 Ladies and Gentlemen:

 In connection with the above-captioned registration statement, and pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), Roth Capital Partners, LLC, as the representative of the underwriters, hereby joins in the request of the Company that the effective date of such registration statement be accelerated to 5:00 p.m. (Eastern time) on Thursday, December 2, 2021, or as soon thereafter as practicable.

 In making this request the undersigned acknowledges that it is aware of its obligations under the Act as they relate to the public offering of securities pursuant to the registration statement.

 Signature Page Follows

   1

    Very truly yours,

   ROTH CAPITAL PARTNERS, LLC,

 As the Representative of the Underwriters

  By:  /s/ Aaron M. Gurewitz

   Name:

  Aaron M. Gurewitz

  Title:  Head of Equity Capital Markets

   2

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celz_corresp.htmCreative Medical Technology Holdings, Inc.
211 E. Osborn Road
Phoenix, Arizona 85012

 November 30, 2021

 Via Edgar

 Ms. Christine Westbrook
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549

   Re:

   Creative Medical Technology Holdings, Inc.

 Registration Statement on Form

 S-1 Filed November 23, 2021

 File No. 333-259834

Dear Ms. Westbrook:

 Pursuant to Rule 461 under the Securities Act of 1933, as amended, Creative Medical Technology Holdings, Inc. hereby requests acceleration of the effective date of the above-referenced Registration Statement to 5:00 p.m. on December 2, 2021, or as soon thereafter as practicable.

 Please contact Zev M. Bomrind of Fox Rothschild LLP, counsel to the Company, at (212) 878-7951, as soon as the registration statement has been declared effective, or if you have any other questions or concerns regarding this matter.

       Sincerely,

    /s/ Timothy Warbington

  Timothy Warbington

      Chief Executive Officer

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 101 Park Avenue
Suite 1700
New York, NY 10178

 Tel (212) 878-7900
Fax (212) 692-0940

 www.foxrothschild.com

 November 23, 2021

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Life Sciences

 100 F Street, N.E.

 Washington, DC 20549

    Attention:

   Christine Westbrook

   Celeste Murphy

   Re:

   Creative Medical Technology Holdings, Inc.

   Registration Statement on Form
S-1 Filed September 28, 2021
File No. 333-259834

 Ladies and Gentlemen:

 On behalf of our client, Creative Medical Technology Holdings, Inc. (the “Company”), we are responding to the comment of the staff (the “Staff”) of the Securities and Exchange Commission contained in its letter dated October 7, 2021 (the “Comment Letter”), relating to the above referenced Registration Statement on Form S-1 (the “Registration Statement”).  In response to the comment set forth in the Comment Letter, the Company has revised the Registration Statement and is filing Amendment No. 1 thereto with this response letter.  In this letter, we have recited the Staff’s comment in italicized, bold type, followed by Company’s response.

 U.S. Securities and Exchange Commission

 November 23, 2021
Page 2

 Cover Page

    1.

   We note your disclosure that the units will be offered at an "assumed" price. We further note that you are subject to the reporting requirements of Section 13(a) or 15(d) of the Exchange Act, as applicable. Please revise to state the price of the securities to the public. If you are not able to state the price, explain the method by which the price is to be determined. Refer to Instruction 2 to Item 501(b)(3) of Regulation S-K.

 We have revised the disclosure in the Registration Statement to remove references to an assumed price per Unit.

 Very truly yours,

 /s/ Zev M. Bomrind

 Zev M. Bomrind

 cc:        Timothy Warbington

United States securities and exchange commission logo
October 7, 2021
Timothy Warbington
Chief Executive Officer
Creative Medical Technology Holdings, Inc.
211 E. Osborn Road
Phoenix, AZ 85012
Re:Creative Medical Technology Holdings, Inc.
Registration Statement on Form S-1
Filed September 28, 2021
File No. 333-259834
Dear Mr. Warbington:
            We have limited our review of your registration statement to those issues we have
addressed in our comment.  In our comment, we may ask you to provide us with information so
we may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our 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 the comment, we may have additional comments.
Registration Statement on Form S-1 filed September 28, 2021
Cover page
1.We note your disclosure that the units will be offered at an "assumed" price. We further
note that you are subject to the reporting requirements of Section 13(a) or 15(d) of the
Exchange Act, as applicable. Please revise to state the price of the securities to the public.
If you are not able to state the price, explain the method by which the price is to be
determined. Refer to Instruction 2 to Item 501(b)(3) of Regulation S-K.
            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.

 FirstName LastNameTimothy Warbington
 Comapany NameCreative Medical Technology Holdings, Inc.
 October 7, 2021 Page 2
 FirstName LastName
Timothy Warbington
Creative Medical Technology Holdings, Inc.
October 7, 2021
Page 2
            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 Celeste Murphy at 202-551-3257 or Christine Westbrook at 202-551-
5019 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Zev M. Bomrind, Esq.

January 31, 2018
Timothy  Warbington
Chief Executive Officer
Creative Medical Technology Holdings, Inc.
2017 W Peoria Avenue
Phoenix, AZ 85029
Creative Medical Technology Holdings, Inc.
Preliminary Information Statement on Schedule 14C
Filed January 12, 2018
File No. 000-53500Re:
Dear Mr. Warbington:
            We have completed our review of your filing.  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 by the staff.
Division of Corporation Finance
Office of Healthcare & Insurance
cc: Brian Higley - Vance, Higley & Associates, P.C.

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Vance,
Higley & Associates, P. C.

Attorneys at Law

1656
Reunion Avenue

SUITE 250

South
Jordan, UTAH 84095

    Ronald N. Vance
    TELEPHONE (801) 446-8802

    Brian M. Higley
    FAX (801) 446-8803

    EMAIL: ron@vancelaw.us

    EMAIL: brian@vancelaw.us

January 30, 2018

Ms. Irene Paik

Ms. Erin Jaskot

U.S. Securities and Exchange Commission

Division of Corporate Finance

Office of Healthcare & Insurance

Washington, DC 20549

 Re: Creative Medical Technology Holdings, Inc.

Amended Preliminary Information
Statement on Schedule 14C

Filed January 23, 2018

File No. 000-53500

Dear Ms. Paik and Ms. Jaskot:

Pursuant to my telephone
conversations with Ms. Paik on January 30, 2018 during which we discussed the final comment to the PRER 14C Information Statement
filed on January 23, 2018 (the “PRER 14C”) by Creative Medical Technology Holdings, Inc., a Nevada corporation
(the “Company”), a DEF 14C Information Statement was filed on January 30, 2018 and the only revision that was
made from the PRER 14C was the following disclosure was revised as follows:

$50,000 Secured
Convertible Note

On June 26,
2017, the Company entered into a convertible note agreement with a lender for an aggregate principal amount of $50,000, for which
$50,000 in proceeds were received on June 26, 2017. Under the terms of the agreement, the convertible note incurs interest at 12%
per annum and has a maturity date of December 26, 2017. The convertible note is convertible upon issuance and convertible into
shares of the Company’s stock at a conversion price equal to or greater than $0.25 or a conversion price equal to 60% of
the average closing trading price of the Company’s common stock during the previous 20 trading days preceding the conversion
date.

The conversion
price is subject to adjustment in the case of stock splits, stock dividends, combinations of shares and similar recapitalization
transactions and any issuances of securities below the conversion price of the convertible note. As of January 8, 2018, 148,553,067 no shares were reserved with our transfer agent with a potential of up to 151,179,304 being reserved if and when the lender
issues a request to our transfer agent.

We hereby acknowledge
the following on behalf of the Company:

 · the Company is responsible for the adequacy and accuracy
of the disclosure in the filing:

Ms. Irene Paik

Ms. Erin Jaskot

Page 2

 · staff comments or changes to disclosure in response
to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

 · the Company may not assert staff comments as a defense
in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please feel free to
contact me if you have any questions on the responses to your comment.

Sincerely,

/s/ Brian Higley

 cc: Timothy Warbington, CEO

Donald
Dickerson, CFO

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Vance,
Higley & Associates, P. C.

Attorneys at Law

1656
Reunion Avenue

SUITE 250

South
Jordan, UTAH 84095

    Ronald N. Vance
    TELEPHONE (801) 446-8802

    Brian M. Higley
    FAX (801) 446-8803

    EMAIL: ron@vancelaw.us

    EMAIL: brian@vancelaw.us

January 23, 2018

Ms. Irene Paik

Ms. Erin Jaskot

U.S. Securities and Exchange Commission

Division of Corporate Finance

Office of Healthcare & Insurance

Washington, DC 20549

 Re: Creative Medical Technology Holdings, Inc.

Preliinary Information
Statement on Schedule 14C

Filed January 12, 2018

File No. 000-53500

Dear Ms. Paik and Ms. Jaskot:

We are in receipt of
your letter dated January 19, 2018, setting forth certain comments to the PRE 14C Information Statement filed on January 12, 2018
by Creative Medical Technology Holdings, Inc., a Nevada corporation (the “Company”). In response to your comments,
the Company can provide you with the following information:

Preliminary Information Statement on
Schedule 14C filed January 12, 2018

Amendment to the Articles of Incorporation
to Increase Authorizes Shares of Common Stock from 600,000,000 to 3,000,000,000

Outstanding Shares and Purpose of the
Amendment, page 3

 1. We note your disclosure that you have entered into a series of financing transactions that require you to maintain a reserve
of shares for conversions of outstanding debt which are at multiples based on your issued and outstanding shares of common stock.
Please expand your disclosure to provide (i) the amount of the newly authorized shares of common stock that will be issued as a
result of conversions of your outstanding debt, (ii) the amount of newly authorized shares of common stock that are required to
be held in reserve under your financing agreements and (iii) the general effect of the issuance of the shares of common stock as
a result of conversions of your outstanding debt upon the rights of existing security holders. Refer to Item 11(c) and (d) and
Note A of Schedule 14A.

RESPONSE: On January 23, 2018,
the Company filed Amendment No. 1 to the PRE 14C Information Statement which added disclosure to page 3 of the PRE 14C Information
Statement under the header on Page 3, “Outstanding Shares and Purpose of the Amendment” which includes
disclosure of each of the notes and their terms which are the reason for the corporate action. Under the header, “Effects
of the Increase in Authorized Common Stock” additional disclosure was added to reference both the effects on common
stock of an increase in authorized and debt conversions.

In addition to the
revision referenced above, the PRE 14C Information Statement has also been amended to update the filing to add disclosure regarding
the creation of the Series A Preferred Stock and the issuance of 3,000,000 shares of Series A Preferred Stock.

We hereby acknowledge
the following on behalf of the Company:

 · the Company is responsible for the adequacy and accuracy of the disclosure in the filing:

 · staff comments or changes to disclosure in response to staff comments do not foreclose the Commission
from taking any action with respect to the filing; and

 · the Company may not assert staff comments as a defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United States.

Please feel free to
contact me if you have any questions on the responses to your comments.

Sincerely,

/s/ Brian Higley

 cc: Timothy Warbington, CEO

Donald Dickerson, CFO

January 19, 2018
Timothy Warbington
Chief Executive Officer
Creative Medical Technology Holdings, Inc.
2017 W Peoria Avenue
Phoenix, AZ 85029
Re:Creative Medical Technology Holdings, Inc.
Preliminary Information Statement on Schedule 14C
Filed January 12, 2018
File No. 000-53500
Dear Mr. Warbington:
            We have reviewed your filing and have the following comment.
            Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Preliminary Information Statement on Schedule 14C filed January 12, 2018
Amendment to the Articles of Incorporation to Increase Authorized Shares of Common Stock
from 600,000,000 to 3,000,000,000
Outstanding Shares and Purpose of the Amendment, page 3
1.We note your disclosure that you have entered into a series of financing transactions that
require you to maintain a reserve of shares for conversions of outstanding debt which are
at multiples based on your issued and outstanding shares of common stock.  Please
expand your disclosure to provide (i) the amount of the newly authorized shares of
common stock that will be issued as a result of conversions of your outstanding debt, (ii)
the amount of newly authorized shares of common stock that are required to be held in
reserve under your financing agreements and (iii) the general effect of the issuance of the
shares of common stock as a result of conversions of your outstanding debt upon the
rights of existing security holders.  Refer to Item 11(c) and (d) and Note A of Schedule
14A.

 FirstName LastNameTimothy  Warbington
 Comapany NameCreative Medical Technology Holdings, Inc.
 June 16, 2017 Page 2
 FirstName LastName
Timothy  Warbington
Creative Medical Technology Holdings, Inc.
January 19, 2018
Page 2
            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.
            Please contact Irene Paik at 202-551-6553 or Erin Jaskot at 202-551-3442 with any
questions.
Division of Corporation Finance
Office of Healthcare & Insurance
cc: Ronald N. Vance - Vance, Higley &Associates, P.C.

THE LAW OFFICE OF
RONALD N. VANCE & ASSOCIATES , P. C.
Attorneys at Law
1656 REUNION AVENUE
SUITE 250
SOUTH JORDAN, UTAH 8 4095

Ronald N. Vance  TELEPHONE (801) 446 -8802
Brian M. Higley  FAX (801) 446 -8803
  EMAIL: ron@vancelaw.us

October 11, 2016

Suzanne Hayes, Assistant Director
Office of Healthcare and Insurance
Division of Corporation Finance
Mail Stop 4720
U.S. Securities and Exchange Commission
Washington, D.C. 20549

 Re: Creative Medical Technology Holdings, Inc.
Amendment No. 1 to Draft Registration Statement on Form S -1
Submitted September 1, 2016
CIK No. 0001187953

Dear Ms. Hayes,

Creative Medical Technology Holdings, Inc. (the “Company”) is in receipt of your letter dated September
30, 2016, in regard to the confiden tial filing of the draft registration statement on Form S -1. In response to the
comments set forth in your letter, I have been authorized by the Company to provide the information below. For
comments to Part I of the registration statement, references to p age numbers are to the page numbers of the
prospectus in the edgar draft of the document.

Prospectus Summary, page 1

 1. We note your statement on page 2 that a procedure to which you compare your treatment for which you
are currently conducting a clinical trial “has been demonstrated safe and feasible in small patient
studies.” This statement seems to imply that your treatment will achieve favorable results in its current
clinical trial or in later trials. Please specify the studies to  which you are referring and provide sufficient
description about these studies, such as their size, endpoints, any material adverse events reported, etc.,
so that readers may evaluate the comparison you make. Please also make clear that in providing this
information, you are not making a conclusion as to the safety and feasibility of your own treatment.

RESPONSE: Management has added language on page 2 of the prospectus to disclose that the prior studies and the case report of a single patient by Dr. Ichim, one of the Company’s directors, would not be indicative of results from
the present clinical trial being performed by the Company. In addition, management has added more detailed
information in the business section of the prospectus on page 20 to disc lose information about the prior trials by
others and the case study by Dr. Ichim. As supplemental information, included with this letter is an article published
by Dr. Ichim in the Journal of Translational Medicine in 2013 in which the prior trials and hi s case study are
described.

Suzanne Hayes, Assistant Director
October 11, 2016
Page 2

Management’s Discussion and Analysis..., page 13

Plan of Operations, page 13

 2. We note your statement that you believe that your current cash on hand would meet your cash flow
requirements for “only a few more months” and that you “currently have no alternative source for
funding.” Please revise to specify the amount of cash currently used in your operations per month and
the length of time that your present resources will support your operations. Also, in light of your
statement regarding no alternative source for funding, please also revise to state whether the cash on
hand will be sufficient to complete your ongoing clinical trial.

RESPONSE: Management has modified and added language on page 13 of the prospectus to clarify its current cash
status and its plans to supplement this with future equity or debt offerings in order to meet its operating expenses
and to complete its  current clinical trial.

Business and Properties, page 16

Creative Medical Technologies, page 17

 3. Please revise to discuss the primary endpoints for each clinical trial that you have commenced.

RESPONSE: Management has added disclosure on page 20 of the prospectus for the endpoints for its current ED
clinical trial, which is the sole trial being conducted presently.

 4. For each of your product candidates, please describe your anticipated developmental timelines.

RESPONSE: Management has added language on pages 20 and 21 of the prospectus to provide estimates of the
timelines for its current product candidates. For the male infertility and female sexual dysfunct ion treatments,
management does not intend to project a timeline for development of the treatments until the patents associated with
these treatments are granted. For both the miscarriage treatment and multipotent amniotic fetal stem cells technology, mana gement intends to pursue FDA trials which management estimates could require up to ten years
and would require significant additional financial resources.

Intellectual Property, page 19

 5. For each patent that you own, license or intend to apply for, please describe the type of patent protection
represented by the application, such as composition of matter, use or process.

RESPONSE: On pages 21 and 22 of the prospectus, management has described the types of patent protection
represented by the patents owned, applied for, or licensed by the Company.

 6. We note that your statement on page 19 indicating that you have entered into a license agreement with
LABIOMED. Please revise your description of this agreement to disclose:
 • the term of the agreement;

Suzanne Hayes, Assistant Director
October 11, 2016
Page 3

 • the circumstances under which the agreement may be terminated; and
 • the aggregate amount of potential future  milestone payments.

RESPONSE: Management has added disclosure in response to the above items on page 21 of the prospectus.

 7. We note that your statement on page 20 indicating that you have entered into a license agreement with
the Regents of The University of California. Please revise your description of this agreement to disclose:
 • the initial license fee;
 • the annual license maintenance fees;
 • royalty rates; and
 • the aggregate amount of potential future milestone payments.

RESPONSE: The information requested by this comment has not been included in the revised draft of the
registration statement submitted herewith. Simultaneous with the confidential submission o f this amended
registration statement, management has submitted to the Commission a request for confidential treatment of this
information. A redacted copy of the agreement is submitted as an exhibit with this submission.

Government Regulation, page 20

 8. We note your statement that “We believe that the above exemption would apply to the ED stem cell
treatment under study and would not require further regulatory compliance.” Please expand your
disclosure to indicate the basis for your conclusion that further regulatory compliance is not required.
Please also include a discussion of the requirements of the Public Health Service Act and how they
would impact your business should the exemption not apply. Fina lly, also revise to clarify whether you
believe such exemption would apply to your other product candidates and the basis for your belief.

RESPONSE: Management has added language on page 22 of the prospectus to this section to further describe the regul atory exemption upon which the Company is relying for its ED treatment, as well as management’s belief of its
application to the Company’s other product candidates, except for the Amniotic stem cell and recurring miscarriage products which management belie ves would not qualify for the exemption.

Competition, page 20

 9. We note your description of competition for your ED products. Please revise to include a description of
competitive conditions in the marketplace and competing products, both commercial and in
development, for each of your other products in development as well.

RESPONSE: Management has revised the language on page 22 of the prospectus to include competitive condition s
with each of this product candidates. The only product currently in development by the Company is the ED treatment.

Suzanne Hayes, Assistant Director
October 11, 2016
Page 4

Management, page 21

Business Experience of Executive Officers and Directors, page 21

 10. In addition to providing background information, for each director or person nominated or chosen to
become a director, briefly discuss the specific experience, qualifications, attributes or skills that led to
the conclusion that the person should serve as a director. Please refer to Item 401(e) of Regulation S -K.

RESPONSE: Management has added language on page  23 of the prospectus in response to Item 401(e) of
Regulation S -K as to the basis for management’s conclusion that led to the selection of each director.

Exhibits, page II -2

 11. Please file a complete copy of your current Articles of Incorporation. Refer to Item 601(b)(3)(i) of
Regulation S -K.

RESPONSE: A complete copy of the Articles of Incorporation has been included in Exhibit 3.1 and is included with
this submission.

 12. Please file as an exhibit the consulting agreement with Dr. Patel noted on page 24 or tell us why this
agreement is not required to be filed. We note that you appear to have a beneficial interest in this
agreement. Please refer to Item 601(b)(10)(i) of Reg ulation S -K.

RESPONSE: Management is still attempting to locate the original agreement between Creative Medical Health, Inc.
(“CMH”), the Company’s parent, and Dr. Patel. Former counsel for CMH recently passed away and management is
continuing to collec t all records held by him, which should include this agreement. Dr. Patel is also attempting to
locate his copy of the agreement. If neither management nor Dr. Patel is able to locate the original agreement, the
parties will execute a recreated agreement w hich memorializes the original terms.

 13. Please file as exhibits the agreements mentioned in the sixth paragraph on page 2 and the license
mentioned in the fourth paragraph on page 3, or tell us why you do not believe these are required to be
filed pursuant to Item 601(b)(10) of Regulation S -K.

RESPONSE: Copies of the UCSD License Agreement, the Master Services Agreement, and the Clinical Trial
Agreement have been added as Exhibits 10.21, 10.22, and 10.23, respectively. The UCSD Licens e Agreement has
been redacted to exclude confidential information and a notation of the removal of this information has been added
in the table of exhibits for Exhibit 10.21.

Financial Statements

Report of Independent Registered Public Accounting Firm,  page F -1

 14. Please have your auditors provide you with a revised audit report that indicates the city and state where
issued in compliance with Article 2 -02(a) of Regulation S -X.

RESPONSE: The city and state location of the auditor has been added to its audit report.

Suzanne Hayes, Assistant Director
October 11, 2016
Page 5

General

 15. Please supplementally provide us with copies of all written communications, as defined in Rule 405
under the Securities Act, that you, or anyone authorized to do so on your behalf, present to potential
investors in reliance on Section 5(d) of the Securities Act, whether or not they retain copies of t he
communications.

RESPONSE: Management has represented that neither the Company nor anyone authorized on its behalf has
furnished any written communications to potential investors in reliance on Section 5(d) of the Securities Act and does not anticipate furnishing such information in connection with this registration.

In addition to the above, the following updates or corrections have been made to this draft of the
registration statement:
 • A few minor corrections have been made to the biographical information of Mr. Dickerson and Dr. Patel on
page 24 of the prospectus.
 • Also, the subsequent event note to the financial statements has been updated and Item 15 of Part II of the
registration statement has been updated to reflect a sale of common shares since the last submission of the
draft registration statement.
 • Likewise, the selling stockholder and the beneficial ownership tables have been revised to reflect the sale of
the shares and percentage ownership amounts.
 • Also, the number of outstanding shares designed in the prospectus summary has been updated.
 • Finally, language has been added to reflect the organization of a new subsidiary of Creative Medical
Technologies, Inc., Amniostem LLC, which has not yet conducted any business activities and holds to
assets. A new Exhibit 21.1 has been added to reflect this additional subsidiary.

Please feel free to contact me if further information on any of these items or otherwise is required.

    Sincerely,

    /s/ Ronald N. Vance

Encl.
cc: Timothy Warbington, CEO
  Donald Dickerson, CFO
  Russ Boyer, CPA
  Haynie & Company

Pages 6 through 33 redacted for the following reasons:
- - - - - - - - - - - - - - - - - - - - - - - - - - - -
***COPYRIGHT MATERIAL OMITTED***

CORRESP
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Creative
Medical Technology Holdings, Inc.

2007 W Peoria Ave

Phoenix, AZ 85029

(602) 680-7439

timwarbington@yahoo.com

December 8, 2016

Suzanne Hayes

Assistant Director

Office of Healthcare and Insurance

Division of Corporation Finance

US Securities and Exchange Commission

 Re: Creative Medical Technology Holdings, Inc.

Registration Statement on Form S-1

File No. 333-214741

Request for Effectiveness

Dear Ms. Hayes:

Pursuant to Rule 461 of Regulation C promulgated
by the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933, as amended (the
“Act”), Creative Medical Technology Holdings, Inc. (the “Company”) hereby requests that the
registration statement of the Company on Form S-1 (Commission File No. 333-214741) be granted an effective date of Monday, December
12, 2016, 11:00 a.m. EST, or as soon thereafter as practicable. We request that we be notified of such effectiveness by a telephone
call or email to our legal counsel, Ronald N. Vance, at (801) 446-8802, ron@vancelaw.us. The Company hereby authorizes Mr. Vance
to orally modify or withdraw this request for acceleration.

This request for acceleration will acknowledge
that the Company is aware of its obligations under the Act and the Securities Exchange Act of 1934, as amended, as they relate
to the proposed public offering of the securities specified in the above registration statement. The Company further acknowledges
that:

 · should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose
the Commission from taking any action with respect to the filing;

 · the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does
not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

 · the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

Please direct any questions or comments
regarding this acceleration request to Mr. Vance.

    Sincerely,

    /s/ Timothy Warbington

    Timothy Warbington, CEO

 cc: Ronald N. Vance, Esq.

Mary Beth Breslin, SEC

CORRESP
1
filename1.htm

THE LAW OFFICE OF

Vance,
Higley & Associates, P. C.

Attorneys at Law

1656
Reunion Avenue

SUITE 250

South
Jordan, UTAH 84095

    Ronald N. Vance
    TELEPHONE (801) 446-8802

    Brian M. Higley
    FAX (801) 446-8803

    EMAIL: ron@vancelaw.us

November 18, 2016

Suzanne Hayes, Assistant Director

Office of Healthcare and Insurance

Division of Corporation Finance

Mail Stop 4720

U.S. Securities and Exchange Commission

Washington, D.C. 20549

Re:         Creative Medical
Technology Holdings, Inc.

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

Submitted October 12, 2016

CIK No. 0001187953

Dear Ms. Hayes,

Creative Medical Technology Holdings, Inc.
(the “Company”) is in receipt of your letter dated November 2, 2016, in regard to the confidential filing of the draft
registration statement on Form S-1. The Company is publicly filing the registration statement with the Commission. In response
to the comments set forth in your letter, I have been authorized by the Company to provide the information below. For comments
to Part I of the registration statement, references to page numbers are to the page numbers of the prospectus in the edgar draft
of the document.

Intellectual Property, page 19

 1. We note your response to our prior comment 7. Please note that although a request for confidential
treatment has been made, you should include a description of the material terms of the agreement. Please revise to disclose the
material terms of the license agreement with the University of California.

RESPONSE: Because management believes that the amount of the
initial license fee and the annual license maintenance fees are not material, no information as to these amounts has been included
in the registration statements. Management has included on page 20 of the prospectus the range of the royalty rates to be paid
under the agreement and the aggregate amount of potential future milestone payments.

Exhibit Index

 2. We note you are seeking confidential treatment of portions of an agreement filed as an
exhibit. Please note we will provide any comments on your application separately.

Suzanne Hayes, Assistant Director

November 18, 2016

Page 2

RESPONSE: A redacted copy of the agreement was filed as an exhibit
to the Company’s quarterly report on Form 10-Q filed with the Commission on November 10, 2016.

In addition to the above, the following
updates or corrections have been made to the prior draft of the registration statement:

 · The financial statements and the financial information in the MD&A
section have been updated to reflect the Company’s financial statements for the period ended September 30, 2016, which were
filed on November 10, 2016, with the Commission in the Company’s quarterly report on Form 10-Q.

 · The number of common shares outstanding has been increased to reflect
recent nonpublic sales of shares by the Company. These numbers are reflected in the tables set forth in the Selling Stockholders
and Security Ownership of Certain Beneficial Owners and Management sections, and in the Prospections Summary section, as well as
the first risk factor under “Risks Related to Our Common Stock” on page 8.

 · The market quotation table in the “Market for Our Common Stock”
section on page 11 has been updated to include the third trading quarter. Also, the number of record owners of the Company’s
common stock has been updated to a more recent date in this section. Further, language has been added to this section under the
subheading “2016 Stock Incentive Plan to reflect two option grants under our stock incentive plan described in this section.

 · Management updated the “Certain Relationships and Related Transactions”
subsection on page 23 to reflect the purchase of shares and warrants by the parent company.

 · In the “Legal Matters” section on page 30, the name of
the law firm representing the Company has been updated to reflect a recent change in name of the firm.

 · Item 15 of Part II has been updated to reflect the recent sales of
unregistered securities.

Further, because this is the
public filing of the draft registration statement previously filed confidentially, management has included the following information:

 · The calculation for the filing fee has been included on the cover
page of the registration statement.

 · A recent trading price of the common stock has been inserted onto
the cover page of the prospectus.

 · Under Part II, Item 13 has been completed to include the estimated
costs of the offering.

 · Each of the exhibits required by Item 601 has been included with this
filing. Three of the exhibits previously filed on a confidential basis, namely the redacted License Agreement with UCSD, the Master
Services Agreement with Professional Research Consulting, Inc., and the Clinical Trial Agreement with LABIOMED, designated as Exhibits
1..21, 10.22, and 10.23, respectively, were filed with the Company’s quarterly report on Form 10-Q filed with the Commission
on November 10, 2016, and are incorporated by reference into this registration statement.

 · Exhibit 10.20, the consulting agreement with Dr. Patel, is a letter
agreement between CMH and Dr. Patel to represent the terms of the original written agreement which neither party can locate. Management
believes that the terms of the letter agreement accurately reflect the terms of the original agreement.

Suzanne Hayes, Assistant Director

November 18, 2016

Page 3

Please feel free to contact me if further
information on any of these items or otherwise is required.

Sincerely,

/s/ Ronald N. Vance

    cc:
    Timothy Warbington, CEO

    Donald Dickerson, CFO

    Russ Boyer, CPA

    Haynie & Company

Mail  Stop 4546
November 2 , 2016

Timothy Warbington
Chief Executive Officer
Creative Medical Technology Holdings, Inc.
2017 W Peoria Avenue
Phoenix, AZ 85029

Re:  Creative Medical Technology Holdings, Inc.
Amendment No. 2 to Draft Registration Statement on Form S -1
Submitted October 12, 2016
CIK No. 0001187953

Dear Mr. Warbington :

We have reviewed your amended draft registration statement  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 this letter by providing the requested information and either submitting
an amended draft registration statement or publicly fili ng your registration statement on
EDGAR.  If you do not believe our comments apply 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 respons e to these  comments  and your
amended draft registration statement or filed registration statement,  we may have  additional
comments.

Intellectual Property, page 19

1. We note your response to our prior comment 7.  Please note that although a request for
confidential treatment has been made, you should include a description of the material
terms of the agreement.  Please revise to disclose the material terms of the licen se
agreement with the University of California.

Exhibit Index

2. We note you are seeking confidential treatment of portions of an agreement filed as an
exhibit. Please note we will provide any comments on your application separately.

Timothy Warbington
Creative Medical Technology Holdings, Inc.
November 2 , 2016
Page 2

You may contact Jame s Peklenk at (202) 551 -3661 or Sharon Blume at (202) 551 -3474 if
you have questions regarding comments on the financial statements and related matters. Please
contact Michael Gershon at (202) 551 -6598 or Mary Beth Breslin at (202) 551 -3625 with any
other q uestions.

Sincerely,

        /s/ Mary Beth Breslin for

Suzanne Hayes
Assistant Director
Office of Healthcare and Insurance

cc:  Ronald N. Vance, Esq.

Mail stop 4546
September 30, 2016

Timothy Warbington
Chief Executive Officer
Creative Medical Technology Holdings, Inc.
2017 W Peoria Avenue
Phoenix, AZ 85029

Re:  Creative Medical Technology Holdings, Inc.
Amendment No. 1 to Draft Registration Statement  on Form S -1
Submitted September 1, 2016
CIK No. 0001187953

Dear Mr. Warbington :

We have reviewed your draft registration statement 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 this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe our comments apply  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 these comments and your
amended draft registration statement or filed registrat ion statement, we may have additional
comments.

Prospectus Summary, page 1

1. We note your statement on page 2 that a procedure to which you compare your treatment
for which you are currently conducting a clinical trial “has been demonstrated safe and
feasible in small patient studies.”  This statement  seems to imply that your treatment will
achieve favorable results in its current clinical trial or in later trials . Please specify the
studies to which  you are referring and provide sufficient description about these studies,
such as their size, endpoints, any material adverse events  reported , etc. , so that readers
may evaluate the comparison you make . Please also make clear that in providing this
information, you are not making a conclusion as to the safety and feasibility of your own
treatment.

Timothy Warbington
Creative Medical Technology Holdings, Inc.
September 30, 2016
Page 2

 Management’s Discussion and Analysis ..., page 13

Plan of Operations, page 13

2. We note your statement that you believe that your current cash on hand would meet your
cash flow requirements for “only a few more months ” and that you “currently have no
alternative source for funding. ”  Please revise to specify the amount of cash currently
used in your operations per month  and the length of time t hat your present resources will
support your operations .  Also, in light of your statement regarding no alternative source
for funding, please also revise to state whether the cash on hand will be sufficient to
complete your ongoing clinical trial.

Business and Properties, page 16

Creative Medical Technologies, page 17

3. Please revise to discuss the primary endpoints for each clinical trial that you have
commenced .

4. For each of your product candidates, please describe your anticipated developmental
timelines.

Intellectual Property, page 19

5. For each patent that you own, license or intend to apply for, please describe the type of
patent protection represented by the application, such as composition of matter, use or
process.

6. We note that your statement on page 19 indicating that you have entered into a license
agreement with LABIOMED.  Please revise your description of this agreemen t to
disclose:
 the term of the agreement;
 the circumstances under which the agreement may be terminated; and
 the aggregate amount of potential future milestone payments .

7. We note that your statement on page 20 indicating that you have entered into a lice nse
agreement with the Regents of  The University of California. Please revise your
description of this agreement to disclose:
 the initial license fee;
 the annual license maintenance fees;
 royalty rates; and
 the aggregate amount of potential future milest one payments.

Timothy Warbington
Creative Medical Technology Holdings, Inc.
September 30, 2016
Page 3

 Government Regulation, page 20

8. We note your statement that “ We believe that the above exemption would apply to the
ED stem cell treatment under study and would not require further regulatory
compliance. ”  Please expand your disclosure to indicat e the basis for your conclusion that
further regulatory complia nce is not required. Please also include a discussion of the
requirements of the Public He alth Service Act and how they would impact your business
should the exemption not apply. Finally, also revise to clarify whether yo u believe such
exemption would apply t o your other product candidates  and the basis for your belief.

Competition, page 20

9. We note your description of competition for your ED products.  Please revise to include a
description of competitive conditions in the marketplace and competing p roducts, both
commercial and in development, for each of your other products in development as well.

Management, page 21

Business Experience of Executive Officers and Directors , page 21

10. In addition to providing background information, for each director  or person nominated
or chosen to become a director, briefly discuss the specific experience, qualifications,
attributes or skills that led to the conclusion that the person should serve as a director.
Please refer to Item 401(e) of Regulation S -K.

Exhibits, page II -2

11. Please file a complete copy of your current Articles of Incorporation . Refer to Item
601(b)( 3)(i) of Regulation S -K.

12. Please  file as an exhibit the consulting agreement with Dr. Patel note d on page 24  or tell
us why this agreement is not required to be filed.  We note that you appear to have a
benefici al interest in this agreement. Please refer to Item 601(b) (10)(i) of Regulation S -K.

13. Please file as exhibits the agreements mentioned in the sixth paragraph on page 2 and the
license mentioned in the fourth paragraph on page 3, or tell us why you do not believe
these are required to be filed  pursuant to Item 601(b)(10) of Regu lation S -K.

Financial Statements

Repo rt of Independent Registered Public Accounting Firm, page F -1

14. Please have your auditors provide you with a revised audit report that indicates the city
and state where issued in compliance with Article 2 -02(a) of Regulation S -X.

Timothy Warbington
Creative Medical Technology Holdings, Inc.
September 30, 2016
Page 4

General

15. Please supplementally provide us with copies of all written communications, as defined
in Rule 405 un der the Securities Act, that you, or anyone authorized to do so on your
behalf, present to potential investors in reliance on Section 5(d) of the Securities Act,
whether or not they retain copies of the communications.

You may contact James Peklenk at (20 2) 551 -3661 or Sharon Blume at (202) 551 -3474 if
you have questions regarding comments on the financial statements and related matters. Please
contact Michael Gershon at (202) 551 -6598 or Mary Beth Breslin at (202) 551 -3625 with any
other questions.

Since rely,

        /s/ Mary Beth Breslin f or

Suzanne Hayes
Assistant Director
Office of Healthcare and Insurance

cc:  Ronald N. Vance, Esq.

Mail Stop 4720
        July 1 , 2016

Timothy Warbington
Chief Executive Officer
Creative Medical Technology Holdings, Inc.
2017 W Peoria Avenue
Phoenix, AZ 85029

Re:      Creative Medical Technology Holdings, Inc.
Draft Registration Statement on Form S -1
Submitted June 20, 2016
            CIK No. 0001187953

Dear Mr. Warbington :

 Our preliminary review of your draft registration statement indicates that it fails to comply
with the requirements of the form.   Specifically, we note the independent audit or’s report of Haynie
& Company  does not refer to the standards of the Public Compan y Accounting Oversight Board .
Refer to Section 4110.5 3b of the Division of Corporation Finance ’s Financial Reporting Manual ,
available on the Commission’s website .  As a result, w e will not perform a detailed examination of
the draft registration statement and we will not issue  commen ts.

 You may submit a substantive amendment to correct the deficienc y.  You may contact Jim
B. Rosenberg, Senior Assistant Chief Accountant, at (202) 551 -3679 if you have questions
regarding comments on the financial statements and related matters.  Please contact Tara Keating
Brooks at (202) 551 -8336 or Mary Beth Breslin at (202) 551 -3625 with any other questions.

        Sincerely,

             /s/ Mary Beth Breslin for

Suzanne Hayes
Assistant Director
Office of Healthcare and Insurance

August 21, 2012

Via E -mail
Mr. Steven L. White
President
Jolley Marketing, Inc.
664 South Alvey Dr.
Mapleton, UT  84664

RE: Jolley Marketing, Inc.
Item 4.01 Form 8 -K
Filed August 13, 2012
File No. 0 -53500

Dear Mr. White :

We have completed our review of your filings.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing s and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing s to be certain that the filing s include the
information the Securities Exchange Act of 1934 and a ll applicable rules require.

Sincerely,

 /s/ Jeffrey Gordon

 Jeffrey Gordon
Staff Accountant

CORRESP
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SEC Response Letter

Jolley Marketing Inc.

664 SOUTH ALVEY DRIVE

MAPLETON, UTAH 84664

Steven L. White

TELEPHONE (801) 489-4802

President

August 17, 2012

Jeffrey Gordon, Staff Accountant

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C.  20549

Re:

Jolley Marketing, Inc.

Item 4.01 Form 8-K

Filed August 13, 2012

File No. 000-53500

Dear Mr. Gordon:

I am in receipt of your letter dated August 14, 2012, in connection with the above-referenced filing by Jolley Marketing, Inc., a Nevada corporation (the “Company”).  In response to the specific comments in your letter dated August 14, 2012, I am authorized to provide the following responses and information, with each numbered item below corresponding to the numbered items in your letter:

1.

Item 304(a)(1)(ii) of Regulation S-K requires a statement whether the accountant's reports on the financial statements for either of the past two years contained an adverse opinion or a disclaimer of opinion or was qualified or modified as to uncertainty, audit scope or accounting principles; and a description of the nature of each such adverse opinion, disclaimer of opinion, modification or qualification. This would include disclosure of uncertainty regarding the ability to continue as a going concern in the accountant’s reports. It appears that the accountant’s reports included in the December 31, 2011 and 2010 Forms 10-K included disclosure of uncertainty regarding the ability to continue as a going concern. As such, please amend your Form 8-K and revise your disclosure accordingly.

RESPONSE:  The Form 8-K filed on August 13, 2012 has been amended to include disclosure of uncertainty regarding the ability to continue as a going concern.

2.

To the extent that you make changes to the Form 8-K to comply with our comments, please obtain and file an updated Exhibit 16 letter from the former accountants stating whether the accountant agrees with the statements made in your amended Form 8-K.

RESPONSE:  The Form 8-K/A filed on August 16, 2012 contains an updated Exhibit 16 letter as referenced in the comment above.

The Company acknowledges that it is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

If further information in this regard is required, please feel free to contact me.

Sincerely,

/s/ Steven L. White

Steven L. White

President

CORRESP
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SEC Response Letter

THE LAW OFFICE OF

RONALD N. VANCE & ASSOCIATES, P. C.

Attorneys at Law

1656 REUNION AVENUE

SUITE 250

SOUTH JORDAN, UTAH 84095

Ronald N. Vance

TELEPHONE (801) 446-8802

Brian M. Higley

FAX (801) 446-8803

EMAIL: ron@vancelaw.us

EMAIL: brian@vancelaw.us

August 16, 2012

Jeffrey Gordon, Staff Accountant

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C.  20549

Re:

Jolley Marketing, Inc.

Item 4.01 Form 8-K

Filed August 13, 2012

File No. 000-53500

Dear Mr. Gordon:

We are in receipt of your letter dated August 14, 2012, in connection with the above-referenced filing by Jolley Marketing, Inc., a Nevada corporation (the “Company”).  In response to the specific comments in your letter dated August 14, 2012, I have been authorized to provide the following responses and information, with each numbered item below corresponding to the numbered items in your letter:

1.

Item 304(a)(1)(ii) of Regulation S-K requires a statement whether the accountant's reports on the financial statements for either of the past two years contained an adverse opinion or a disclaimer of opinion or was qualified or modified as to uncertainty, audit scope or accounting principles; and a description of the nature of each such adverse opinion, disclaimer of opinion, modification or qualification. This would include disclosure of uncertainty regarding the ability to continue as a going concern in the accountant’s reports. It appears that the accountant’s reports included in the December 31, 2011 and 2010 Forms 10-K included disclosure of uncertainty regarding the ability to continue as a going concern. As such, please amend your Form 8-K and revise your disclosure accordingly.

RESPONSE:  The Form 8-K filed on August 13, 2012 has been amended to include disclosure of uncertainty regarding the ability to continue as a going concern.

2.

To the extent that you make changes to the Form 8-K to comply with our comments, please obtain and file an updated Exhibit 16 letter from the former accountants stating whether the accountant agrees with the statements made in your amended Form 8-K.

RESPONSE:  The Form 8-K/A filed on August 16, 2012 contains an updated Exhibit 16 letter as referenced in the comment above.

Jeffrey Gordon, Staff Accountant

Division of Corporation Finance

August 16, 2012

Page 2

The Company has authorized me to convey to you that it acknowledges that it is responsible for the adequacy and accuracy of the disclosure in the filing, staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing, and the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

If further information in this regard is required, please feel free to contact the Company or this office.

Sincerely,

/s/ Brian M. Higley

Brian M. Higley

Encl.

cc:

Steven L. White, President

August 14, 2012

Via E -mail
Mr. Steven L. White
President
Jolley Marketing, Inc.
664 South Alvey Dr.
Mapleton, UT  84664

RE: Jolley Marketing, Inc.
Item 4.01 Form 8 -K
Filed August 13, 2012
File No. 0 -53500

Dear Mr. White :

We have reviewed your filing an d 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 r espond to this letter within five  business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comments  apply 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 filing and the information you provide in
response to these  comments, we may have  additional  comments.

1. Item 304(a)(1)(ii) of Regulation S -K requires a statement whether the accountant's reports on
the financial statements for either of the past two years contain ed an adverse opinion or a
disclaimer of opinion or was qualified or modified as to uncertainty, audit scope or
accounting principles; and a description of the nature of each such adverse opinion,
disclaimer of opinion, modification or qualification.  This  would include disclosure of
uncertainty regarding the ability to continue as a going concern in the accountant’s report s.  It
appears that the accountant’s reports included in the December 31 , 2011  and 201 0 Forms 10 -
K included disclosure of uncertainty regard ing the ability to continue as a going concern.  As
such, please amend your Form 8 -K and revise your disclosure accordingly.

2. To the extent that you make changes to the Form 8 -K to comply with our comments, please
obtain and file an updated Exhibit 16 lett er from the former accountants stating whether the
accountant agrees with the statements made in your amended Form 8 -K.

Mr. Steven  L. White
Jolley Marketing, Inc.
August  14, 201 2
Page 2

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of t he disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the  federal securities laws of the United States.
You may  contact me at (202) 551 -3866 with any questions.

 Sincerely,

        /s/ Jeffrey Gordon

 Jeffrey Gordon
 Staff Accountant