SecProbe.io

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 Coeptis Therapeutics Holdings, Inc.

 105 Bradford Rd, Suite 420

 Wexford, Pennsylvania 15090

 April 18, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Life Sciences

 100 F Street, N.E.

 Washington, DC 20549

 Attention: Joshua Gursky

 Re: Coeptis Therapeutics Holdings, Inc.

 Registration Statement on Form S-1

 Filed on January 10, 2025

 File No. 333-284230

 Ladies and Gentlemen:

 Pursuant to Rule 461 of the General Rules and Regulations
under the Securities Act of 1933, as amended, the undersigned, Coeptis Therapeutics Holdings, Inc., a Delaware corporation (the "Registrant"),
hereby requests acceleration of the effective date of the above-referenced Registration Statement such that it may become effective on
Monday, April 21, 2025, at 5:00 p.m. Eastern Time.

 The Registrant hereby acknowledges that:

 (i) should
the Securities and Exchange Commission (the "Commission") or the staff, acting pursuant to delegated authority, declare the
Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

 (ii) the
action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does
not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement;
and

 (iii) the
Registrant may not assert the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration
Statement effective as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the
United States.

 Once the Registration
Statement has been declared effective, please orally confirm that event with our counsel, Meister Seelig & Fein PLLC ,
by calling Denis Dufresne at (212) 655-3548 (also can be reached at dad@msf-law.com).

 Thank you for your assistance in this matter.

 Very truly yours,

 COEPTIS
THERAPEUTICS HOLDINGS, Inc.

 By: 	 /s/ David Mehalick

 Name: David Mehalick

 Title: Chief Executive Officer

 cc: Denis Dufresne, Esq., Meister Seelig & Fein
PLLC

January 16, 2025
David Mehalick
Chief Executive Officer
Coeptis Therapeutics Holdings, Inc.
105 Bradford Road, Suite 420
Wexford Pennsylvania 15090
Re:Coeptis Therapeutics Holdings, Inc.
Registration Statement on Form S-1
Filed January 10, 2025
File No. 333-284230
Dear David Mehalick:
            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 Tamika Sheppard at 202-551-8346 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Denis Dufresne

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Coeptis Therapeutics
Holdings, Inc.

105 Bradford Rd, Suite 420

Wexford, Pennsylvania 15090

November 28, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, N.E.

Washington, DC 20549

Attention: Lauren S. Hammil

 Re: Coeptis Therapeutics Holdings, Inc.

    Registration Statement on Form S-1

    Filed on November 15, 2023

    File No. 333-275558

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations
under the Securities Act of 1933, as amended, the undersigned, Coeptis Therapeutics Holdings, Inc., a Delaware corporation (the “Registrant”),
hereby requests acceleration of the effective date of the above-referenced Registration Statement such that it may become effective tomorrow,
November 29, 2023, at 5:00 p.m. Eastern Time.

The Registrant hereby acknowledges that:

(i)should
the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the
Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

(ii)the
action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does
not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement;
and

(iii)the
Registrant may not assert the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration
Statement effective as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the
United States.

Once the Registration
Statement has been declared effective, please orally confirm that event with our counsel, Meister Seelig & Fein PLLC,
by calling Denis Dufresne at (212) 655-3548 (also can be reached at dad@msf-law.com).

Thank you for your assistance in this matter.

Very truly yours,

COEPTIS
THERAPEUTICS HOLDINGS, Inc.

By:      /s/ David Mehalick

Name: David Mehalick

Title:   Chief Executive Officer

cc: Denis Dufresne, Esq., Meister Seelig & Fein
PLLC

United States securities and exchange commission logo
November 22, 2023
David Mehalick
Chief Executive Officer
Coeptis Therapeutics Holdings, Inc.
105 Bradford Road , Suite 420
Wexford, PA 15090
Re:Coeptis Therapeutics Holdings, Inc.
Registration Statement on Form S-1
Filed November 15, 2023
File No. 333-275558
Dear David Mehalick:
            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 Lauren Hamill at 303-844-1008 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Denis Dufresne

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June 12, 2023

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Attention: Timothy Buchmiller

  Re:
  Coeptis Therapeutics Holdings, Inc.

  Registration Statement on Form S-1

  File No. 333-260782

Ladies and Gentlemen:

As representative of the underwriters
of the proposed public offering of securities of Coeptis Therapeutics Holdings, Inc. (the “Company”), we hereby join
the Company’s request that the effective date of the above-referenced Registration Statement on Form S-1 be accelerated so that
it will be declared effective at 5:30 p.m., Eastern Time, on Tuesday, June 13, 2023, or at such later time as the Company or its counsel
may orally request via telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange Commission.

Pursuant to Rule 460 under
the Act, we, as representative of the underwriters, wish to advise you that there will be distributed to each underwriter or dealer, who
is reasonably anticipated to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus
as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned advises that
it has complied and will continue to comply, and that it has been informed by the participating underwriters and dealers that they have
complied with and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Remainder of Page Intentionally Left Blank]

      1

  Very truly yours,

Ladenburg Thalmann & Co. Inc.

  By: /s/ Nicholas Stergis

  Name: Nicholas Stergis

  Title: Managing Director

  cc:
  David Mehalick, Coeptis Therapeutics Holdings, Inc.

  Richard A. Friedman, Sheppard, Mullin, Richter
& Hampton LLP

  Denis Dufrense, Esq. Meister Seeling & Fein
PLLC

      2

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Coeptis Therapeutics Holdings, Inc.

105 Bradford Rd, Suite 420

Wexford, Pennsylvania 15090

June 12, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Attention: Timothy Buchmiller

 Re: Coeptis Therapeutics Holdings, Inc.

    Registration Statement on Form S-1

    File No. 333-260782

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations
under the Securities Act of 1933, as amended, Coeptis Therapeutics Holdings, Inc. (the “Company”) respectfully requests that
the effective date of the Registration Statement referred to above be accelerated so that it will become effective at 4:30p.m. Eastern
Time, on, June 13, 2023, at 5:30 p.m., or at such later time as the Company or its counsel may orally request via telephone call to the
staff of the Division of Corporation Finance of the Securities and Exchange Commission.

Please notify Denis
Dufresne of Meister Seelig & Fein PLLC, counsel to the Company at (212) 655-3548 as soon as possible
as to the time the Registration Statement has been declared effective pursuant to this acceleration request.

Thank you for your assistance in this matter.

  Very truly yours,

  COEPTIS
THERAPEUTICS HODINGS, Inc.

  By:
  /s/ David Mehalick

  Name:
  David Mehalick

  Title:
  Chief Executive Officer

United States securities and exchange commission logo
February 23, 2023
David Mehalick
Chief Executive Officer
Coeptis Therapeutics Holdings, Inc.
105 Bradford Road, Suite 420
Wexford Pennsylvania 15090
Re:Coeptis Therapeutics Holdings, Inc.
Registration Statement on Form S-1
Filed February 14, 2023
File No. 333-269782
Dear David Mehalick:
            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 Tim Buchmiller at (202) 551-3635 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Denis Dufresne, Esq.

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Bull Horn Holdings Corp.

801 S. Pointe Drive, Suite TH-1

Miami Beach, Florida 33139

VIA EDGAR

September 29, 2022

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, NE

Washington, D.C. 20549

    Attention:
    Joshua Gorsky

    Tim Buchmiller

    Nudrat Salik

    Tracey Houser

    Re:
    Bull Horn Holdings Corp.

    Amendment No. 6 to Registration Statement on Form S-4 (the “Registration Statement”)

    Submitted September 29, 2022

    File No. 333-265206

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act
of 1933, as amended, Bull Horn Holdings Corp. hereby requests acceleration of effectiveness of the above referenced Registration Statement
so that it will become effective at 4:00 p.m. ET on September 30, 2022, or as soon as practicable thereafter.

    Sincerely,

    /s/ Robert Striar

    Name:
    Robert Striar

    Title:
    Chief Executive Officer

    cc:
    Ellenoff Grossman & Schole LLP

    Meister Seelig & Fein LLP

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Bull Horn Holdings Corp.

801 S. Pointe Drive, Suite TH-1

Miami Beach, Florida 33139

VIA EDGAR

September 26, 2022

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, NE

Washington, D.C. 20549

    Attention:
    Joshua Gorsky

    Tim Buchmiller

    Nudrat Salik

    Tracey Houser

    Re:
    Bull Horn Holdings Corp.

    Amendment No. 4 to Registration Statement on Form S-4

    Filed September 12, 2022

    File No. 333-265206

Ladies and Gentlemen:

Bull Horn Holdings Corp. (the
“Company,” “Bull Horn,” “we,” “our” or “us”)
hereby transmits its response to the comment letter received from the staff (the “Staff”) of the U.S. Securities and
Exchange Commission (the “Commission”) on September 22, 2022, regarding Amendment No. 4 to the Registration Statement
on Form S-4 filed with the Commission on September 12, 2022 (the “Registration Statement”).

For the Staff’s convenience,
we have repeated below the Staff’s comments in bold, and have followed each comment with the Company’s response. Disclosure
changes made in response to the Staff’s comments have been made in Amendment No. 5 to the Registration Statement (the “Amended
Registration Statement”), which is being filed with the Commission contemporaneously with the submission of this letter.

Amendment No. 4 to Registration Statement on Form S-4, filed
September 12, 2022

Nasdaq may delist the Company's securities from trading on its
exchange..., page 44

 1. We note your disclosure regarding Nasdaq Listing Rules 5505(a) and 5505(b)(2). Please revise this disclosure to more accurately
convey all of the requirements of these listing rules or, alternatively, revise your disclosure to note that your description of the rules
is not a full restatement of the rules. For example, you note that under Nasdaq Listing Rule 5505(a), the Company’s minimum stock
price would need to be at least $4.00 per share and that the Company will be required to have a minimum of “300 public holders of
‘rounder lots’ of 100 shares[,]” but you do not mention that the Company will need to have, among other things, at least
1,000,000 Unrestricted Publicly Held Shares.

In response to the Staff’s comment,
we have revised the disclosure on page [  ] of the Amended Registration Statement.

U.S. Securities and Exchange Commission

Division of Corporation Finance

September 26, 2022

Page 2

 2. We note the portion of your response to comment 5 from our August 10, 2022 letter that the Nasdaq staff may have preliminarily
indicated that you may use the operating history of Coeptis to meet the operating history requirement while using the trading price of
the Bull Horn ordinary shares for the share price requirement. Since it appears from your response that you will be relying on Nasdaq
Listing Rules 5505(a)(1)(A) and (b)(2), we do not take a position on using the operating history of Coeptis to meet the operating history
requirement while using the trading price of the Bull Horn ordinary shares for the share price requirement in order to meet the Nasdaq
listing requirements, and have no further comments at this time.

We hereby acknowledge the Staff’s comment.

* * *

We thank the Staff for its
review of the foregoing and the Amended Registration Statement. If you have any questions or require additional information, please do
not hesitate to contact our counsel, Joshua N. Englard, at jenglard@egsllp.com or by telephone at (212) 370-1300.

    Sincerely,

    /s/ Robert Striar

    Name:
    Robert Striar

    Title:
    Chief Executive Officer

    cc:
    Ellenoff Grossman & Schole LLP

    Meister Seelig & Fein LLP

United States securities and exchange commission logo
September 22, 2022
Robert Striar
Chief Executive Officer
Bull Horn Holdings Corp.
801 S. Pointe Drive, Suite TH-1
Miami Beach, Florida 33139
Re:Bull Horn Holdings Corp.
Amendment No. 4 to Registration Statement on Form S-4
Filed September 12, 2022
File No. 333-265206
Dear Mr. Striar:
            We have reviewed your amended 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 amending your registration statement and providing the
requested information.  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 registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our August 31, 2022 letter.
Amendment No. 4 to Registration Statement on Form S-4, filed September 12, 2022
Nasdaq may delist the Company's securities from trading on its exchange..., page 44
1.We note your disclosure regarding Nasdaq Listing Rules 5505(a) and 5505(b)(2).  Please
revise this disclosure to more accurately convey all of the requirements of these listing
rules or, alternatively, revise your disclosure to note that your description of the rules is
not a full restatement of the rules.  For example, you note that under Nasdaq Listing Rule
5505(a), the Company’s minimum stock price would need to be at least $4.00 per share
and that the Company will be required to have a minimum of “300 public holders of
‘rounder lots’ of 100 shares[,]” but you do not mention that the Company will need to
have, among other things, at least 1,000,000 Unrestricted Publicly Held Shares.

 FirstName LastNameRobert Striar
 Comapany NameBull Horn Holdings Corp.
 September 22, 2022 Page 2
 FirstName LastName
Robert Striar
Bull Horn Holdings Corp.
September 22, 2022
Page 2
Closing Conditions, page 95
2.We note the portion of your response to comment 5 from our August 10, 2022 letter that
the Nasdaq staff may have preliminarily indicated that you may use the operating history
of Coeptis to meet the operating history requirement while using the trading price of the
Bull Horn ordinary shares for the share price requirement.  Since it appears from your
response that you will be relying on Nasdaq Listing Rules 5505(a)(1)(A) and (b)(2), we do
not take a position on using the operating history of Coeptis to meet the operating history
requirement while using the trading price of the Bull Horn ordinary shares for the share
price requirement in order to meet the Nasdaq listing requirements, and have no further
comments at this time.
            You may contact Nudrat Salik at 202-551-3692 or Tracey Houser at 202-551-3736 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Joshua Gorsky at 202-551-7836 or Tim Buchmiller at 202-551-3635 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joshua N. Englard, Esq.

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Bull Horn Holdings Corp.

801 S. Pointe Drive, Suite TH-1

Miami Beach, Florida 33139

VIA EDGAR

September 12, 2022

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, NE

Washington, D.C. 20549

    Attention:
    Joshua Gorsky

    Tim Buchmiller

    Nudrat Salik

    Tracey Houser

    Re:
    Bull Horn Holdings Corp.

    Amendment No. 3 to Registration Statement on Form S-4

    Filed August 22, 2022

    File No. 333-265206

Ladies and Gentlemen:

Bull Horn Holdings Corp. (the
“Company,” “Bull Horn,” “we,” “our” or “us”)
hereby transmits its response to the comment letter received from the staff (the “Staff”) of the U.S. Securities and
Exchange Commission (the “Commission”) on August 31, 2022, regarding Amendment No. 3 to the Registration Statement
on Form S-4 filed with the Commission on August 22, 2022 (the “Registration Statement”).

For the Staff’s convenience,
we have repeated below the Staff’s comments in bold, and have followed each comment with the Company’s response. Disclosure
changes made in response to the Staff’s comments have been made in Amendment No. 4 to the Registration Statement (the “Amended
Registration Statement”), which is being filed with the Commission contemporaneously with the submission of this letter.

Amendment No. 3 to Registration Statement on Form S-4

Closing Conditions, page 95

 1. Please
note that we continue to evaluate your responses to prior comments 4 and 5 and may have additional comments.

We acknowledge that the Staff continues
to evaluate our responses to prior comments 4 and 5.

Information About Coeptis

Collaborations for Product Development - Research and Development,
page 181

 2. We
note your disclosure that “[t]he global multiple myeloma market was $19.48 billion in 2018 and is expected to reach $31 billion
by 2026.” We direct you to prior comment 41 from our June 22, 2022 letter. Please revise to disclose the countries or jurisdictions
where Vy-Gen is seeking regulatory approval for its drug product candidates and disclose the total addressable market in those countries
and jurisdictions.

In response to the Staff’s comment,
we have revised the disclosure on pages 181 and 186 of the Amended Registration Statement.

U.S. Securities and Exchange Commission

Division of Corporation Finance

September 12, 2022

Page 2

Statera BioPharma, page 183

 3. We
note your disclosure on page 183 that in August 2022, Coeptis and Statera mutually agreed to terminate their “strategic agreement.”
In an appropriate location, please revise your disclosure to indicate how, if at all, this development impacted the Bull Horn board of
directors’ view of the consideration to be paid for the Business Combination, the Vantage Point Opinion that supported the amount
of the consideration to be paid for Coeptis, and the Bull Horn board of directors’ conclusions that the Merger Agreement, the Business
Combination and the Plans of Merger, were advisable, fair to, and in the best interests of, Bull Horn and its shareholders.

We respectfully advise the Staff that
the Vantage Point Opinion did not attribute substantive value to the strategic agreement with Statera because the agreement merely gave
Coeptis the exclusive right to negotiate a definitive agreement and the consummation of the transaction with Statera was contingent upon
the successful negotiation of a definitive agreement and satisfaction of a number of closing conditions, including a financing contingency.
Accordingly, the termination of the strategic agreement did not have an impact on the Bull Horn board of directors’ view of the
consideration to be paid for the Business Combination, the Vantage Point Opinion that supported the amount of the consideration to be
paid for Coeptis, and the Bull Horn board of directors’ conclusions that the Merger Agreement and the Business Combination were
advisable, fair to, and in the best interests of, Bull Horn and its shareholders. We have added disclosure on page 116 of the Amended
Registration Statement to clarify the foregoing.

* * *

We thank the Staff for its
review of the foregoing and the Amended Registration Statement. If you have any questions or require additional information, please do
not hesitate to contact our counsel, Joshua N. Englard, at jenglard@egsllp.com or by telephone at (212) 370-1300.

    Sincerely,

    /s/ Robert Striar

    Name:
    Robert Striar

    Title:
    Chief Executive Officer

    cc:
    Ellenoff Grossman & Schole LLP

    Meister Seelig & Fein LLP

United States securities and exchange commission logo
August 31, 2022
Robert Striar
Chief Executive Officer
Bull Horn Holdings Corp.
801 S. Pointe Drive, Suite TH-1
Miami Beach, Florida 33139
Re:Bull Horn Holdings Corp.
Amendment No. 3 to Registration Statement on Form S-4
Filed August 22, 2022
File No. 333-265206
Dear Mr. Striar:
            We have reviewed your amended 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 amending your registration statement and providing the
requested information.  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 registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our August 10, 2022 letter.
Amendment No. 3 to Registration Statement on Form S-4
Closing Conditions, page 95
1.Please note that we continue to evaluate your responses to prior comments 4 and 5 and
may have additional comments.
Information About Coeptis
Collaborations for Product Development - Research and Development, page 181
2.We note your disclosure that "[t]he global multiple myeloma market was $19.48 billion in
2018 and is expected to reach $31 billion by 2026."  We direct you to prior comment 41
from our June 22, 2022 letter.  Please revise to disclose the countries or jurisdictions
where Vy-Gen is seeking regulatory approval for its drug product candidates and disclose

 FirstName LastNameRobert Striar
 Comapany NameBull Horn Holdings Corp.
 August 31, 2022 Page 2
 FirstName LastName
Robert Striar
Bull Horn Holdings Corp.
August 31, 2022
Page 2
the total addressable market in those countries and jurisdictions.
Statera BioPharma, page 183
3.We note your disclosure on page 183 that in August 2022, Coeptis and Statera mutually
agreed to terminate their "strategic agreement."  In an appropriate location, please revise
your disclosure to indicate how, if at all, this development impacted the Bull Horn board
of directors' view of the consideration to be paid for the Business Combination, the
Vantage Point Opinion that supported the amount of the consideration to be paid for
Coeptis, and the Bull Horn board of directors' conclusions that the Merger Agreement, the
Business Combination and the Plans of Merger, were advisable, fair to, and in the best
interests of, Bull Horn and its shareholders.
            You may contact Nudrat Salik at 202-551-3692 or Tracey Houser at 202-551-3736 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Joshua Gorsky at 202-551-7836 or Tim Buchmiller at 202-551-3635 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joshua N. Englard, Esq.

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Bull
Horn Holdings Corp.

801
S. Pointe Drive, Suite TH-1

Miami
Beach, Florida 33139

VIA
EDGAR

August 22, 2022

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Life Sciences

100
F Street, NE

Washington,
D.C. 20549

    Attention:
    Joshua
    Gorsky

    Tim
    Buchmiller

    Nudrat
    Salik

    Tracey
    Houser

    Re:
    Bull
    Horn Holdings Corp.

    Amendment
    No. 2 to Registration Statement on Form S-4

    Filed
    July 28, 2022

    File
    No. 333-265206

Ladies
and Gentlemen:

Bull Horn Holdings Corp. (the
“Company,” “Bull Horn,” “we,” “our” or “us”)
hereby transmits its response to the comment letter received from the staff (the “Staff”) of the U.S. Securities and
Exchange Commission (the “Commission”) on August 10, 2022, regarding Amendment No. 2 to the Registration Statement
on Form S-4 filed with the Commission on July 28, 2022 (the “Registration Statement”).

For
the Staff’s convenience, we have repeated below the Staff’s comments in bold, and have followed each comment with the Company’s
response. Disclosure changes made in response to the Staff’s comments have been made in Amendment No. 3 to the Registration Statement
(the “Amended Registration Statement”), which is being filed with the Commission contemporaneously with the submission
of this letter.

Amendment
No. 2 to Registration Statement on Form S-4

What
interests do the sponsor and Bull Horn’s officers and directors and its financial advisors have in the Business Combination?, page 22

    1.
    We
    note your new disclosure regarding a potential financing in connection with the Business Combination with Northland acting as placement
    agent. When known, disclose if the SPAC’s sponsors, directors, officers or their affiliates will participate in the potential financing.

We respectfully advise the Staff that
none of the Company’s sponsor, directors, officers or their affiliates anticipates participating in the potential financing.

Unaudited
Pro Forma Condensed Combined Financial Information, page 28

    2.
    We
    note your response to comment 1. Please specifically address your consideration of the modification guidance provided in ASC 718
    in regards to the exchange of warrants and whether there is any impact of this guidance that needs to be reflected in the pro forma
    financial information.

We
respectfully advise the Staff that we considered ASC 718-20-35-2A which notes modification accounting is required if (1) the fair value,
(2) the vesting conditions, or (3) the classification of the award (as equity or liability) changes as a result of the change in terms
or conditions. We further considered the limited guidance of ASC 718-20-35-6 and the broader guidance in ASC 805. As none of the conditions
noted in ASC 718-20-35-2A exist for the warrants that are being assumed and absent a scenario further noted in ASC 718 or ASC 805, we
do not believe that there is an impact to the pro forma financial information in regard to the exchange of warrants.

U.S. Securities and Exchange Commission

Division of Corporation Finance

August 22, 2022

Page 2

    3.
    We
    note your response to comment 2. Your disclosures continue to state that you are still determining whether or not this transaction
    will be pursued, which appears inconsistent with your assertion that the acquisition is probable. Please revise your disclosures
    as necessary. Please also provide disclosures regarding your basis for determining that these assets will have an alternative future
    use and should be reflected as an asset rather than expense in the pro forma financial information pursuant to ASC 730-10-25-2.

We respectfully advise the Staff that
the proposed transaction has been terminated and all references to this transaction in the pro forma financial information have been eliminated.

Risk
Factors

Nasdaq
may delist the Company’s securities from trading on its exchange . . ., page 44

    4.
    We
    note your disclosure that in order to continue to maintain the listing of the Company’s securities on Nasdaq, the Company’s
    stock price would generally be required to be at least $4 per share. Please tell us in your response whether you are referring to
    Nasdaq Listing Rule 5550(a)(2) in this regard and revise your disclosure as appropriate. Additionally, please revise your disclosure
    to address that the shares of Coeptis Therapeutics, Inc.’s common stock are currently trading at a price below $4.00 per share
    and to describe the material risk that the Company’s common shares could be delisted by Nasdaq if the Company is unable to
    maintain a minimum price of $1.00 per share, if applicable, or, if the Company is listing under the alternative initial listing requirements,
    that the Company could be monitored by Nasdaq for penny stock issues. See Nasdaq IM-5505-2. Alternatively, please tell us why no
    such disclosure is needed.

We respectfully advise the Staff that
this risk factor was referring to the initial listing requirements in Nasdaq Listing Rule 5505, which the combined company will need to
meet in connection with the business combination. We have revised the disclosure on page 44 of the Amended Registration Statement in response
to the Staff’s comment and to clarify both the initial and continued listing requirements of the Nasdaq Capital Market.

Closing
Conditions, page 94

    5.
    We
    note your response to prior comment 4. Given that Coeptis Therapeutics, Inc. is a publicly traded company, with a current trading
    price below $4.00 per share, please provide us with your analysis as to how using the bid price of Bull Horn’s ordinary shares
    immediately prior to the closing of the business combination satisfies the applicable Nasdaq share price requirement. We also note
    that while you intend to use the trading price of the Bull Horn shares to meet the share price requirement, you also intend to use
    the operating history of Coeptis to meet the operating history requirement. Please also provide us with your analysis as to how using
    the trading price of the Bull Horn ordinary shares for the share price requirement, while using the Coeptis operating history for
    the operating history requirement, satisfies the applicable Nasdaq listing requirement. Please cite the specific trading price and
    operating history listing standards you intend to rely upon to list. When appropriate, please tell us whether Nasdaq has preliminarily
    approved your listing application based on the referenced standards.

We respectfully advise the Staff that
we intend to satisfy the Market Value of Listed Securities Standard of the Nasdaq Capital Market set forth in Nasdaq Listing Rules 5505(a)
and (b)(2). We have discussed these listing requirements with the Nasdaq staff, who have confirmed that they will look to Bull Horn’s
per share trading price (rather than Coeptis’ share price) immediately prior to the closing of the business combination to determine
satisfaction of the applicable Nasdaq $4.00 minimum share price requirement. Separately, the Nasdaq staff has confirmed that we may use
the operating history of Coeptis to meet the operating history requirement while using the trading price of the Bull Horn ordinary shares
for the share price requirement. In any event, the Market Value of Listed Securities Standard under which we seek to list does not include
an operating history requirement.

U.S. Securities and Exchange Commission

Division of Corporation Finance

August 22, 2022

Page 3

Description
of Negotiation Process with Coeptis, page 99

    6.
    We
    note your response to prior comment 8 and your revised disclosure on page 100. Please revise your disclosure further to describe
    the nature of the consultations that Bull Horn had with JonesTrading and Bridgeway regarding the initial valuation of Coeptis.

In
response to the Staff’s comment, we have revised the disclosure on pages 100 and 101 of the Amended Registration Statement.

Financial
Statements of Coeptis Therapeutics Inc.

Note
3. License Right, page F-49

    7.
    We
                                                         note your response to comment 11 and the proposed disclosures provided. We continue to believe more detailed disclosures need to be
                                                         provided regarding the significant judgments made and basis for those judgments in determining the Co-Development Options have
                                                         alternative future use and should be recorded as assets pursuant to ASC 730- 10-25-2. The responses dated June 9, 2022 and July 7,
                                                         2022 from Coeptis Therapeutics addressed multiple of these judgments including that the pursuit of FDA approval for the use of CD38
                                                         assets for at least one indication or medical device approval is at least reasonably expected as well as that there are third
                                                         parties interested in the technologies which would enable you to sell your rights or sell the CD38 assets upon the written consent
                                                         of Vy-Gen Bio, which cannot be reasonably withheld.

We have been advised that Coeptis previously
received a similar comment from the Staff in connection with its review of Coeptis’ Annual Report on Form 10-K for the year ended
December 31, 2021. We understand that Coeptis has recently had calls with, and exchanged correspondence with, the Staff to pre-clear revisions
to the referenced Note 3, with the understanding that these pre-cleared changes would be then incorporated into the Amended Registration
Statement. Accordingly, we have revised the disclosure on pages F-64 and F-65 of the Amended Registration Statement, with specific reference
to Note 3 – License Right, regarding the Co-Development Options, to address the significant judgements that were made and
the determination that the options have an alternative future use and were recorded as assets pursuant to ASC 730-10-25-2.

Exhibits

    8.
    Please
    ensure that you also provide an updated consent in a subsequent amendment from the auditors of Bull Horn Holdings Corporation. See
    Item 601(b)(23) of Regulation S-K.

In
response to the Staff’s comment, an updated consent from our auditors has been filed as Exhibit 23.1 to the Amended Registration
Statement.

*
* *

U.S. Securities and Exchange Commission

Division of Corporation Finance

August 22, 2022

Page 4

We
thank the Staff for its review of the foregoing and the Amended Registration Statement. If you have any questions or require additional
information, please do not hesitate to contact our counsel, Joshua N. Englard, at jenglard@egsllp.com or by telephone at (212) 370-1300.

    Sincerely,

    /s/
    Robert Striar

    Name:
    Robert
    Striar

    Title:
    Chief
    Executive Officer

    cc:
    Ellenoff
    Grossman & Schole LLP

    Meister
    Seelig & Fein LLP

United States securities and exchange commission logo
August 10, 2022
Robert Striar
Chief Executive Officer
Bull Horn Holdings Corp.
801 S. Pointe Drive, Suite TH-1
Miami Beach, Florida 33139
Re:Bull Horn Holdings Corp.
Amendment No. 2 to Registration Statement on Form S-4
Filed July 28, 2022
File No. 333-265206
Dear Mr. Striar:
            We have reviewed your amended 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 amending your registration statement and providing the
requested information.  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 registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our July 20, 2022 letter.
Amendment No. 2 to Registration Statement on Form S-4
What interests do the sponsor and Bull Horn's officers and directors and its financial advisors
have in the Business Combination?, page 22
1.We note your new disclosure regarding a potential financing in connection with the
Business Combination with Northland acting as placement agent.  When known, disclose
if the SPAC's sponsors, directors, officers or their affiliates will participate in the potential
financing.
Unaudited Pro Forma Condensed Combined Financial Information, page 28
2.We note your response to comment 1.  Please specifically address your consideration of
the modification guidance provided in ASC 718 in regards to the exchange of warrants

 FirstName LastNameRobert Striar
 Comapany NameBull Horn Holdings Corp.
 August 10, 2022 Page 2
 FirstName LastNameRobert Striar
Bull Horn Holdings Corp.
August 10, 2022
Page 2
and whether there is any impact of this guidance that needs to be reflected in the pro
forma financial information.
3.We note your response to comment 2.  Your disclosures continue to state that you are still
determining whether or not this transaction will be pursued, which appears inconsistent
with your assertion that the acquisition is probable.  Please revise your disclosures as
necessary.  Please also provide disclosures regarding your basis for determining that these
assets will have an alternative future use and should be reflected as an asset rather than
expense in the pro forma financial information pursuant to ASC 730-10-25-2.
Risk Factors
Nasdaq may delist the Company's securities from trading on its exchange . . ., page 44
4.We note your disclosure that in order to continue to maintain the listing of the Company’s
securities on Nasdaq, the Company’s stock price would generally be required to be at least
$4 per share.  Please tell us in your response whether you are referring to Nasdaq Listing
Rule 5550(a)(2) in this regard and revise your disclosure as appropriate.  Additionally,
please revise your disclosure to address that the shares of Coeptis Therapeutics, Inc.’s
common stock are currently trading at a price below $4.00 per share and to describe the
material risk that the Company’s common shares could be delisted by Nasdaq if the
Company is unable to maintain a minimum price of $1.00 per share, if applicable, or, if
the Company is listing under the alternative initial listing requirements, that the Company
could be monitored by Nasdaq for penny stock issues.  See Nasdaq IM-5505-2.
 Alternatively, please tell us why no such disclosure is needed.
Closing Conditions, page 94
5.We note your response to prior comment 4.  Given that Coeptis Therapeutics, Inc. is a
publicly traded company, with a current trading price below $4.00 per share, please
provide us with your analysis as to how using the bid price of Bull Horn’s ordinary shares
immediately prior to the closing of the business combination satisfies the applicable
Nasdaq share price requirement.  We also note that while you intend to use the trading
price of the Bull Horn shares to meet the share price requirement, you also intend to use
the operating history of Coeptis to meet the operating history requirement.  Please also
provide us with your analysis as to how using the trading price of the Bull Horn ordinary
shares for the share price requirement, while using the Coeptis operating history for the
operating history requirement, satisfies the applicable Nasdaq listing requirement.  Please
cite the specific trading price and operating history listing standards you intend to rely
upon to list.  When appropriate, please tell us whether Nasdaq has preliminarily approved
your listing application based on the referenced standards.
Description of Negotiation Process with Coeptis, page 99
6.We note your response to prior comment 8 and your revised disclosure on page 100.
Please revise your disclosure further to describe the nature of the consultations that Bull

 FirstName LastNameRobert Striar
 Comapany NameBull Horn Holdings Corp.
 August 10, 2022 Page 3
 FirstName LastName
Robert Striar
Bull Horn Holdings Corp.
August 10, 2022
Page 3
Horn had with JonesTrading and Bridgeway regarding the initial valuation of Coeptis.
Financial Statements of Coeptis Therapeutics Inc.
Note 3. License Right, page F-49
7.We note your response to comment 11 and the proposed disclosures provided.  We
continue to believe more detailed disclosures need to be provided regarding the significant
judgments made and basis for those judgments in determining the Co-Development
Options have alternative future use and should be recorded as assets pursuant to ASC 730-
10-25-2.  The responses dated June 9, 2022 and July 7, 2022 from Coeptis Therapeutics
addressed multiple of these judgments including that the pursuit of FDA approval for the
use of CD38 assets for at least one indication or medical device approval is at least
reasonably expected as well as that there are third parties interested in the technologies
which would enable you to sell your rights or sell the CD38 assets upon the written
consent of Vy-Gen Bio, which cannot be reasonably withheld.
Exhibits
8.Please ensure that you also provide an updated consent in a subsequent amendment from
the auditors of Bull Horn Holdings Corporation.  See Item 601(b)(23) of Regulation S-K.
            You may contact Nudrat Salik at 202-551-3692 or Tracey Houser at 202-551-3736 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Joshua Gorsky at 202-551-7836 or Tim Buchmiller at 202-551-3635 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joshua N. Englard, Esq.

CORRESP
1
filename1.htm

Bull Horn Holdings Corp.

801 S. Pointe Drive, Suite TH-1

Miami Beach, Florida 33139

VIA EDGAR

July 27, 2022

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, NE

Washington, D.C. 20549

    Attention:
    Joshua Gorsky

    Tim Buchmiller

    Nudrat Salik

    Tracey Houser

    Re:
    Bull Horn Holdings Corp.

    Amendment No. 1 to Registration Statement on Form S-4

    Filed July 6, 2022

    File No. 333-265206

Ladies and Gentlemen:

Bull Horn Holdings Corp. (the
“Company,” “Bull Horn,” “we,” “our” or “us”)
hereby transmits its response to the comment letter received from the staff (the “Staff”) of the U.S. Securities and
Exchange Commission (the “Commission”) on July 20, 2022, regarding Amendment No. 1 to Registration Statement on Form
S-4 filed with the Commission on July 6, 2022 (the “Registration Statement”).

For the Staff’s convenience,
we have repeated below the Staff’s comments in bold, and have followed each comment with the Company’s response. Disclosure
changes made in response to the Staff’s comments have been made in Amendment No. 2 to the Registration Statement (the “Amended
Registration Statement”), which is being filed with the Commission contemporaneously with the submission of this letter.

Amendment No. 1 to Registration Statement on Form S-4

Unaudited Pro Forma Condensed Combined Financial Information,
page 28

 1. We note your response to prior comment 8. We note the additional disclosures provided on page 29 related
to these warrants. Please further expand your disclosures to explain your basis for not attributing any value to the assumed warrants
to purchase 1,319,197 shares.

In response to the Staff’s comment,
we have revised the disclosure on page 36 of the Amended Registration Statement.

 2. We note your response to prior comment 11. We remind you that Rule 11-01(a)(8) of Regulation S-X states
that you should reflect transactions that have occurred or are probable of occurring. Based on the additional disclosures provided, including
that Coeptis is in the process of performing its due diligence of the applicable assets and therefrom determining whether or not this
transaction will be pursued, it is not clear how you determined this transaction was probable. Please further advise or revise your disclosures
as necessary.

In response to the Staff’s comment,
we have revised the disclosure on page 37 of the Amended Registration Statement.

U.S. Securities and Exchange Commission

Division of Corporation Finance

July 27, 2022

Page 2

 3. We note your response to prior comment 15. It appears that $1.75 million of deferred underwriting fees
of the total $6.7 million transaction expenses were forgiven. It is not clear why there is an adjustment of $6.7 million to cash and how
the forgiveness of this amount is reflected in your pro forma financial information. Please advise and revise your disclosures as necessary.

In response to the Staff’s comment,
we have revised the disclosure on page 36 of the Amended Registration Statement.

Closing Conditions, page 94

 4. We note your response to prior comment 21 and your revised disclosure on page 94 of the registration
statement noting that you intend to qualify for listing on the Nasdaq Capital Market. Given the current trading price of Coeptis Therapeutics’
stock, please tell us in a response how you anticipate meeting the $4.00 per share requirement. Additionally, please specify the precise
Nasdaq listing standard that the combined company anticipates it will qualify under. If you anticipate that the combined company will
qualify under the Nasdaq Capital Market equity standard, please explain how you plan to fulfill the requirement that the combined company
have a two year operating history. If you intend to rely upon a different listing standard, please tell us which one and how you intend
to qualify under that standard. Finally, please tell us whether you have engaged with Nasdaq in any discussions about whether the combined
company would qualify for listing. If so, please tell us what information was shared between you and Nasdaq during those discussions.

We respectfully advise the Staff that
we have been engaged in preliminary discussions with the staff of the Nasdaq Stock Market (the “Nasdaq Staff”) regarding the
Company’s continued listing on the Nasdaq Capital Market. We believe that the combined company will qualify for listing under either
the equity standard or the market value standard applicable to the Nasdaq Capital Market for the reasons set forth below.

Specifically, we believe that the $4.00
per share requirement (the “Share Price Requirement”) can be satisfied based on the bid price of Bull Horn’s ordinary
shares immediately prior to the closing of the business combination with Coeptis Therapeutics, Inc. (the “Business Combination”).
As of the close of business on July 25, 2022, the bid price of Bull Horn’s ordinary shares was $10.14, which significantly exceeds
the Share Price Requirement. We expect the price of the ordinary shares to continue to substantially exceed the Share Price Requirement
at least until the closing of the Business Combination, in which case, the Share Price Requirement would be satisfied.

We believe that the two-year operating
history requirement under the equity standard will be satisfied as Coeptis commenced its operations in 2019 and has in fact filed audited
financial statements with the Commission for the years ended December 31, 2019, 2020 and 2021.

U.S. Securities and Exchange Commission

Division of Corporation Finance

July 27, 2022

Page 3

Under
the maximum redemption scenario set forth in the Amended Registration Statement, a minimum of 996,557 Bull Horn public shares will remain
outstanding after the closing of the Business Combination. In addition, it is anticipated that the public stockholders of Coeptis will
receive approximately 11.4 million of the 17,123,288 shares of common stock to be issued to the stockholders
of Coeptis in connection with the Business Combination. Accordingly, we anticipate that the combined company will have a minimum of approximately
12.4 million shares of common stock held by public stockholders, which would satisfy the number of unrestricted publicly held shares required
under the equity standard. Assuming a minimum share price of $10.00 immediately prior to the closing of the Business Combination, we expect
that the public float of the combined company will substantially exceed the $15 million requirement under the equity standard.

Under the maximum redemption scenario
set forth in the Amended Registration Statement, the stockholders’ equity of the combined company will equal $5 million, which will
satisfy the requirement under the equity standard.

We anticipate that the combined company
will have no fewer than 300 unrestricted round lot stockholders immediately after the closing of the Business Combination. As of July
21, 2022, Coeptis alone had 465 stockholders of record, which amount does not include the companies’ beneficial holders as well
as other investors that may become equity holders of the companies prior to the consummation of the Business Combination.

Alternatively, we believe that we will
also qualify under the market value standard, which requires a minimum market value of listed securities of $50 million (the “Market
Value Requirement”). Under the maximum redemption scenario set forth in the Amended Registration Statement, we will have a minimum
of 996,557 Bull Horn public shares outstanding after the closing of the Business Combination. In addition, Bull Horn’s sponsor will
hold 1,875,000 shares and Coeptis’ stockholders will be receiving approximately 17,123,288 shares in connection with the Business
Combination, which will result in a minimum aggregate of 19,994,845 shares outstanding upon the closing of the Business Combination. Assuming
a minimum share price of $10.00 immediately prior to the closing of the Business Combination, we believe our minimum market value upon
the closing of the Business Combination will substantially exceed the Market Value Requirement.

We plan to continue discussions with
the Nasdaq Staff to assure that the combined company satisfies the appropriate Nasdaq listing requirements.

 5. We also note your revised disclosure in response to prior comment 21 that Nasdaq listing is a closing
condition that could be waived by the parties without recirculation or resolicitation unless you determine that such waiver would render
the disclosure previously disclosed to Bull Horn’s shareholders materially misleading. Please provide us with your analysis as to
why recirculation or resolicitation would not be required if this condition were waived. Please include in your analysis why the holders
of the public shares would not view the listing on Nasdaq as a material part of their voting decision or decision as to whether to exercise
their redemption rights.

In response to the Staff’s comment,
we have revised the disclosure on page 94 of the Amended Registration Statement to clarify that the Nasdaq closing condition could not
be waived without recirculation or resolicitation.

U.S. Securities and Exchange Commission

Division of Corporation Finance

July 27, 2022

Page 4

Description of Negotiation Process with
Candidates Other Than Coeptis, page 98

 6. We note your response to prior comment 26 and your revised disclosure about how the PIPE market was
less favorable in March 2022. Please provide further disclosure about how and why the PIPE market was "less favorable in March 2022
for companies such as Company D, compared to the market conditions in earlier 2022 and in 2021."

In response to the Staff’s comment,
we have revised the disclosure on page 99 of the Amended Registration Statement.

Description of Negotiation Process with
Coeptis, page 99

 7. We note your response to prior comment 28 and your revised disclosure about how Bull Horn expanded
its search to targets in various other industries. Please provide further disclosure regarding the other industries that Bull Horn explored
and explain why Bull Horn's management believed that a transaction with Coeptis provided a more compelling opportunity and created greater
shareholder value than targets in other potential industries.

In response to the Staff’s comment,
we have revised the disclosure on page 99 of the Amended Registration Statement.

 8. We note your response to prior comment 30. Please provide further disclosure regarding the valuation
negotiations between Bull Horn and Coeptis. For example, please disclose who proposed the valuation and how the parties agreed to the
$175 million purchase price that was contemplated by the LOI.

In response to the Staff’s comment,
we have revised the disclosure on page 100 of the Amended Registration Statement.

Collaborations for Product Development -
Research and Development

Vy-Gen Bio, Inc., page 180

 9. We note your disclosure that the CD38-GEAR-NK drug product candidate is designed to enable combination
therapy with anti-CD38 mAbs. Please clarify whether Vy-Gen has entered into or is actively pursuing a license and/or collaboration/supply
agreement with developers of anti-CD38 mAbs, or whether Vy-Gen will need such agreements to further develop or commercialize a combination
therapy using CD38-GEAR-NK with anti-CD38 mAbs. Please include risk factor disclosure if appropriate. If you have determined that such
agreements will not be necessary to further develop or commercialize such a combination therapy, please explain your reasoning.

We respectfully advise the Staff
that there are several potential strategies for commercialization, which may or may not require a collaboration agreement. The
CD38-GEAR-NK product may be marketed non-exclusively as a product that protects NK cells when used with anti-CD38 therapies. In this
case, a prescriber will have the choice to use CD38-GEAR-NK with an anti-CD38 mAb, if appropriate, as an adjunctive therapy. This is
common in oncology and does not require a license from the marketing authorization holder of the primary treatment. It may be
marketed exclusively as a product that protects NK cells when used with a specific anti-CD38 therapy. Vy-Gen is currently pursuing
the appropriate agreements with third party service providers that will be needed to further develop efforts. Accordingly, we have
revised the disclosure on pages 180 and 185 of the Amended Registration Statement to clarify that third
party license or collaboration agreements are not required in order for Vy-Gen to develop the product to commercial use and that no
licenses or collaborations are currently being actively pursued. However, we do not believe that third-party strategic
relationships (whether through license, collaboration or otherwise) warrant additional risk factor disclosure beyond the general
drug development risk factors that are already included in the Amended Registration Statement.

U.S. Securities and Exchange Commission

Division of Corporation Finance

July 27, 2022

Page 5

Our Growth Strategy, page 182

 10. We note your response to prior comment 43 and your revised disclosure regarding Coeptis' relationship
with Vy-Gen. Please provide further disclosure regarding the "active co-development role" set forth in the Co-Development and
Steering Committee Agreement. For example, please describe the types of activities that the joint steering committee engages in and explain
whether this committee has an active role in any research and development activities.

In response to the Staff’s comment,
we have revised the disclosure on pages 182 and 186 of the Amended Registration Statement.

Financial Statements of Coeptis Therapeutics
Inc.

Note 3 – License Right, page F-49

 11. Please expand your disclosures regarding the Co-Development Options to address the significant judgments
made and your basis for these judgments in determining that these options have alternative future use and should be recorded as assets
pursuant to ASC 730-10-25-2.

In response to the Staff’s comment,
(i) Coeptis will add the following disclosure in its Quarterly Report on Form 10-Q for the period ended June 30, 2022 and (ii) such disclosure
will also be added in a subsequent amendment to the Amended Registration Statement that will include financial statements for the three
and six months ended June 30, 2022:

During the year ended December 31, 2021,
the Company and VyGen-Bio, Inc. (“Vy-Gen”) entered into agreements to jointly develop and commercialize two Vy-Gen product
candidates, CD38-GEAR-NK and CD38-Diagnostic (the “CD38 Assets”). The Company paid $1,750,000 and issued promissory notes
totaling $3,250,000 to Vy-Gen in accordance with the agreements. The collaboration arrangement provides the right for the Company to participate,
under the direction of a joint steering committee, in the development and commercialization of the CD38 Assets and a 50/50 profit share,
with the profit share subject to contingent automatic downward adjustment up to 25% upon an event of default in connection with the promissory
notes. The Company has determined that these options have alternative future use and should be recorded as assets pursuant to ASC 730-10-25-2.
The Company capitalized $5,000,000 to be amortized over a five-year period in which the CD38 Assets are expected to contribute to future
cash flows. As of June 30, 2022, the balance due under the two promissory notes totaled $1,500,000, with a maturity date of September
30, 2022.

Related to the joint development, Coeptis,
under the direction of the joint steering committee, is assessing market opportunities, intellectual property protection, and potential
regulatory strategies for the CD38 Assets. VyGen Bio is responsible for development activities conducted and overseen by the scientists
at Karolinska Institute. The agreement does not currently require a

United States securities and exchange commission logo
July 20, 2022
Robert Striar
Chief Executive Officer
Bull Horn Holdings Corp.
801 S. Pointe Drive, Suite TH-1
Miami Beach, Florida 33139
Re:Bull Horn Holdings Corp.
Amendment No. 1 to Registration Statement on Form S-4
Filed July 6, 2022
File No. 333-265206
Dear Mr. Striar:
            We have reviewed your amended 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 amending your registration statement and providing the
requested information.  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 registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our June 22, 2022 letter.
Amendment No. 1 to Registration Statement on Form S-4
Unaudited Pro Forma Condensed Combined Financial Information, page 28
1.We note your response to prior comment 8.  We note the additional disclosures provided
on page 29 related to these warrants.  Please further expand your disclosures to explain
your basis for not attributing any value to the assumed warrants to purchase
1,319,197 shares.
2.We note your response to prior comment 11.  We remind you that Rule 11-01(a)(8) of
Regulation S-X states that you should reflect transactions that have occurred or are
probable of occurring.  Based on the additional disclosures provided, including
that Coeptis is in the process of performing its due diligence of the applicable assets and
therefrom determining whether or not this transaction will be pursued, it is not clear how

 FirstName LastNameRobert Striar
 Comapany NameBull Horn Holdings Corp.
 July 20, 2022 Page 2
 FirstName LastNameRobert Striar
Bull Horn Holdings Corp.
July 20, 2022
Page 2
you determined this transaction was probable.  Please further advise or revise your
disclosures as necessary.
3.We note your response to prior comment 15.  It appears that $1.75 million of deferred
underwriting fees of the total $6.7 million transaction expenses were forgiven.  It is not
clear why there is an adjustment of $6.7 million to cash and how the forgiveness of this
amount is reflected in your pro forma financial information.  Please advise and revise your
disclosures as necessary.
Closing Conditions, page 94
4.We note your response to prior comment 21 and your revised disclosure on page 94 of the
registration statement noting that you intend to qualify for listing on the Nasdaq Capital
Market.  Given the current trading price of Coeptis Therapeutics’ stock, please tell us in a
response how you anticipate meeting the $4.00 per share requirement.  Additionally,
please specify the precise Nasdaq listing standard that the combined company anticipates
it will qualify under.  If you anticipate that the combined company will qualify under the
Nasdaq Capital Market equity standard, please explain how you plan to fulfill the
requirement that the combined company have a two year operating history.  If you intend
to rely upon a different listing standard, please tell us which one and how you intend to
qualify under that standard.  Finally, please tell us whether you have engaged with Nasdaq
in any discussions about whether the combined company would qualify for listing.  If so,
please tell us what information was shared between you and Nasdaq during those
discussions.
5.We also note your revised disclosure in response to prior comment 21 that Nasdaq listing
is a closing condition that could be waived by the parties without recirculation or
resolicitation unless you determine that such waiver would render the disclosure
previously disclosed to Bull Horn’s shareholders materially misleading.  Please provide us
with your analysis as to why recirculation or resolicitation would not be required if this
condition were waived.  Please include in your analysis why the holders of the public
shares would not view the listing on Nasdaq as a material part of their voting decision or
decision as to whether to exercise their redemption rights.
Description of Negotiation Process with Candidates Other Than Coeptis, page 98
6.We note your response to prior comment 26 and your revised disclosure about how the
PIPE market was less favorable in March 2022.  Please provide further disclosure about
how and why the PIPE market was "less favorable in March 2022 for companies such as
Company D, compared to the market conditions in earlier 2022 and in 2021."
Description of Negotiation Process with Coeptis, page 99
7.We note your response to prior comment 28 and your revised disclosure about how Bull
Horn expanded its search to targets in various other industries.  Please provide further
disclosure regarding the other industries that Bull Horn explored and explain why Bull

 FirstName LastNameRobert Striar
 Comapany NameBull Horn Holdings Corp.
 July 20, 2022 Page 3
 FirstName LastNameRobert Striar
Bull Horn Holdings Corp.
July 20, 2022
Page 3
Horn's management believed that a transaction with Coeptis provided a more compelling
opportunity and created greater shareholder value than targets in other potential
industries.
8.We note your response to prior comment 30.  Please provide further disclosure
regarding the valuation negotiations between Bull Horn and Coeptis.  For example, please
disclose who proposed the valuation and how the parties agreed to the $175 million
purchase price that was contemplated by the LOI.
Collaborations for Product Development - Research and Development
Vy-Gen Bio, Inc., page 180
9.We note your disclosure that the CD38-GEAR-NK drug product candidate is designed to
enable combination therapy with anti-CD38 mAbs.  Please clarify whether Vy-Gen has
entered into or is actively pursuing a license and/or collaboration/supply agreement with
developers of anti-CD38 mAbs, or whether Vy-Gen will need such agreements to further
develop or commercialize a combination therapy using CD38-GEAR-NK with anti-CD38
mAbs.  Please include risk factor disclosure if appropriate.  If you have determined that
such agreements will not be necessary to further develop or commercialize such a
combination therapy, please explain your reasoning.
Our Growth Strategy, page 182
10.We note your response to prior comment 43 and your revised disclosure regarding
Coeptis' relationship with Vy-Gen.  Please provide further disclosure regarding the "active
co-development role" set forth in the Co-Development and Steering Committee
Agreement.  For example, please describe the types of activities that the joint steering
committee engages in and explain whether this committee has an active role in any
research and development activities.
Financial Statements of Coeptis Therapeutics Inc.
Note 3 – License Right, page F-49
11.Please expand your disclosures regarding the Co-Development Options to address the
significant judgments made and your basis for these judgments in determining that these
options have alternative future use and should be recorded as assets pursuant to ASC 730-
10-25-2.
Exhibits
Exhibit 99.1 - Form of Proxy Card for Shareholders, page II-2
12.We note the form of preliminary proxy card filed as Exhibit 99.1.  Please note that the
form of proxy should be filed as an appendix to the proxy statement rather than as an
exhibit to the registration statement.  Refer to Note to paragraph (a)(3) of Exchange Act
Rule 14a-4.  In your next amendment please mark your form of proxy card as
preliminary.  In addition, please revise the preliminary proxy card to clarify that the

 FirstName LastNameRobert Striar
 Comapany NameBull Horn Holdings Corp.
 July 20, 2022 Page 4
 FirstName LastName
Robert Striar
Bull Horn Holdings Corp.
July 20, 2022
Page 4
approval of certain proposals are conditioned upon the approval of other specified
proposals.  See Rule 14a-4(a)(3) of Regulation 14A.
            You may contact Nudrat Salik at 202-551-3692 or Tracey Houser at 202-551-3736 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Joshua Gorsky at 202-551-7836 or Tim Buchmiller at 202-551-3635 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joshua N. Englard, Esq.

CORRESP
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filename1.htm

Bull Horn Holdings Corp.

801 S. Pointe Drive, Suite TH-1

Miami Beach, Florida 33139

VIA EDGAR

July 5, 2022

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, NE

Washington, D.C. 20549

    Attention:
    Joshua Gorsky

    Tim Buchmiller

    Nudrat Salik

    Tracey Houser

    Re:
    Bull Horn Holdings Corp.

    Registration Statement on Form S-4

    Filed May 25, 2022

    File No. 333-265206

Ladies and Gentlemen:

Bull Horn Holdings Corp. (the
“Company,” “Bull Horn,” “we,” “our” or “us”)
hereby transmits its response to the comment letter received from the staff (the “Staff”) of the U.S. Securities and
Exchange Commission (the “Commission”) on June 22, 2022, regarding the Registration Statement on Form S-4 filed with
the Commission on May 25, 2022 (the “Registration Statement”).

For the Staff’s convenience,
we have repeated below the Staff’s comments in bold, and have followed each comment with the Company’s response. Disclosure
changes made in response to the Staff’s comments have been made in Amendment No. 1 to the Registration Statement (the “Amended
Registration Statement”), which is being filed with the Commission contemporaneously with the submission of this letter.

Registration Statement on Form S-4 filed
May 25, 2022

Frequently Used Terms, page iii

 1. Please delete any terms that
                                            are not used in the registration statement, such as the defined term “Coeptis warrants,”
                                            or revise as appropriate.

In response to the Staff’s comment,
we have revised the disclosure on pages iii, iv and vi of the Amended Registration Statement.

Anticipated Accounting Treatment, page
8

 2. Your disclosures on page 8
                                            regarding the planned accounting treatment do not appear consistent with those disclosed
                                            on page 29. Specifically on page 8 you indicate that the transaction will be accounted for
                                            as a business combination and any excess of the purchase price over the fair value of net
                                            assets and other identifiable intangible assets acquired will be recorded as goodwill. Please
                                            revise your disclosures as necessary.

In response to the Staff’s comment,
we have revised the disclosure on pages 8 and 29 of the Amended Registration Statement.

U.S. Securities and Exchange Commission

Division of Corporation Finance

July 5, 2022

Page 2

Interests of the Sponsor, Directors and
Officers in the Business Combination, page 8

 3. Please quantify here and in
                                            other relevant sections of the registration statement the aggregate dollar amount of what
                                            the sponsor and its affiliates have at risk that depends on completion of a business combination.
                                            Please ensure that the aggregate amount you disclose includes the current value of securities
                                            held, loans extended, fees due, and out-of-pocket expenses for which the sponsor and its
                                            affiliates are awaiting reimbursement, if any. Provide similar disclosure for the company’s
                                            officers and directors, if material.

In response to the Staff’s comment,
we have revised the disclosure on pages 9, 22, 23, 42, 68, 96 and 97 of the Amended Registration Statement.

Questions and Answers

Why am I receiving this proxy statement/prospectus?,
page 13

 4. We note your disclosure on
                                            page 7 that “[t]he presence, in person virtually or by proxy, of Bull Horn shareholders
                                            representing at least 50% of the ordinary shares issued and outstanding on the Record Date
                                            and entitled to vote on the Proposals to be considered at the Shareholders Meeting will constitute
                                            a quorum for the Shareholders Meeting.” However, on page 14, you note that “[t]he
                                            presence, in person virtually or by proxy, of Bull Horn shareholders representing a majority
                                            of the issued and outstanding ordinary shares on the Record Date and entitled to vote on
                                            the Proposals to be considered at the Shareholders Meeting will constitute a quorum for the
                                            Shareholders Meeting.” Please reconcile.

In response to the Staff’s comment,
we have revised the disclosure on pages 7, 14 and 69 of the Amended Registration Statement.

What equity stake will current Bull Horn
shareholders and Coeptis stockholders hold..., page 18

 5. Please include footnotes to
                                            the table provided to disclose the number of shares associated with Bull Horn warrants and
                                            Coeptis warrants and convertible debt to be outstanding at the completion of the Business
                                            Combination. Confirm to us that the shares included in the table will be issued and outstanding
                                            at the completion of the Business Combination.

In response to the Staff’s comment,
we have revised the disclosure on page 18 of the Amended Registration Statement. We hereby confirm that the shares included in the table
will be issued and outstanding at the completion of the Business Combination.

May the sponsor, Bull Horn’s directors,
officers, advisors or their affiliates purchase shares in connection with the Business Combination?, page 24

 6. We note your disclosure that
                                            “[p]ursuant to the Insider Letter Agreement, the sponsor has agreed to waive its Redemption
                                            Rights with respect to the founder shares and any public shares purchased during or after
                                            the IPO in connection with the consummation of the Business Combination.” Please describe
                                            any consideration provided in exchange for this agreement.

In response to the Staff’s comment,
we have revised the disclosure on page 24 of the Amended Registration Statement.

U.S. Securities and Exchange Commission

Division of Corporation Finance

July 5, 2022

Page 3

Unaudited Pro Forma Condensed Combined
Financial Information, page 28

 7. Please expand your disclosures
                                            to include all the material terms of the transaction, including quantification of the Merger
                                            Consideration based on the facts and circumstances presently known for each component, the
                                            number of new shares of Bull Horn common stock to be issued to Coeptis stockholders and to
                                            be issued to Coeptis warrant holders, and the number of new shares of Bull Horn common stock
                                            the Permitted Debt is convertible into. Also disclose that all other outstanding equity instruments
                                            of Coeptis will be terminated/cancelled without compensation, if correct. Please confirm
                                            that the outstanding unpaid transaction expenses and transaction bonuses have been reflected
                                            in the pro forma financial information.

In response to the Staff’s comment,
we have revised the disclosure on page 29 of the Amended Registration Statement. We hereby confirm that the outstanding unpaid transaction
expenses and transaction bonuses have been reflected in the pro forma financial information.

 8. We note your disclosures regarding
                                            the merger, including on page 3, indicate that certain issued and outstanding warrants to
                                            acquire shares of Coeptis stock will be assumed by Bull Horn and converted into a warrant
                                            for shares of Bull Horn common stock. Please address what consideration was given to reflecting
                                            these warrants in the pro forma financial information.

In response to the Staff’s comment,
we have revised the disclosure on pages vi, 29 and 36 of the Amended Registration Statement. We expect there to be warrants to purchase
1,319,197 shares as a result of the conversion of Coeptis warrants to Bull Horn warrants (Assumed Warrants), which will be equity classified
instruments. The footnotes to the pro forma financial information have been revised to include the disclosure of these warrants. As the
inclusion of these warrants in the calculation of earnings per share is anti-dilutive, they do not impact the weighted average share calculation
or the earnings per share calculation.

 9. We note your disclosures on
                                            page 1 indicate that the sponsor agreed to lend Bull Horn $66,667 per month, or up to $400,000,
                                            to deposit into the trust account in connection with the extension of Bull Horn’s termination
                                            date from May 3, 2022 to November 3, 2022. Please address what consideration was given to
                                            reflecting this loan in the pro forma financial information.

In response to the Staff’s comment,
we have revised the disclosure on page 32 of the Amended Registration Statement to reflect that $200,001 has been borrowed by Bull Horn
from the sponsor.

 10. Please address what consideration
                                            was given to reflecting the impact of the Domestication transaction in the pro forma financial
                                            information.

The Company reviewed the impact of
the Domestication as part of the initial filing and determined that the only impact would be additional transaction costs and the conversion
of ordinary shares into common stock which are included in the pro forma financial information.

U.S. Securities and Exchange Commission

Division of Corporation Finance

July 5, 2022

Page 4

 11. We note your disclosures on
                                            page F-68 indicating that Coeptis entered into an agreement with Statera Biopharma, Inc.
                                            for the acquisition by Coeptis of Statera’s toll-like receptor 5 (TLR5) agonist platform
                                            for $6 million. Please address what consideration you gave to reflecting this transaction
                                            in your pro forma financial information pursuant to Rule 11- 01(a) of Regulation S-X.

As of the initial filing date of the
Registration Statement, we did not consider the state of the potential acquisition of Statera Biopharma by Coeptis to be at a sufficient
stage to include in the pro forma financial information. In response to the Staff’s comment, we have revised the pro-forma unaudited
financial statements on pages 32 and 37 of the Amended Registration Statement to reflect the agreement with Statera Biopharma, Inc.

Adjustments to Unaudited Pro Forma Condensed
Combined Balance Sheets, page 36

 12. It appears that the $32,738
                                            adjustment to additional paid-in capital is part of Adjustment (3) rather than (2). Please
                                            advise or revise as necessary.

In response to the Staff’s comment, we have changed the footnote
identifier to (3) on page 32 of the Amended Registration Statement.

 13. For adjustment (4) related
                                            to the payment of estimated legal, financial advisory and other professional fees, we note
                                            the adjustment to cash and cash equivalents, prepaid expenses and other current expenses
                                            and deferred underwriting fee payable. It would appear that there should also be an adjustment
                                            to accumulated deficit. Please advise or revise as necessary.

In response to the Staff’s comment,
we have revised the disclosure on page 36 of the Amended Registration Statement.

 14. For adjustment (6), please
                                            provide all of the disclosures required by Rule 11-02 (a)(11)(ii)(B) of Regulation S-X regarding
                                            your incomplete accounting. Tell us your consideration for disclosing any corresponding impact
                                            to the pro forma statement of operations related to the change in fair value of warrants.

The expected share structure of the
Company post-Business Combination is expected to be a single class structure which removes the primary reason the warrants are currently
liability classified. There may be other provisions within the warrant agreement, such as the settlement amount not being at fair value,
that may still require liability treatment for the warrants. The Company has not made a formal determination with respect to this guidance
and believes the presentation reflecting continued liability treatment of its warrants to be appropriate. In response to the Staff’s
comment, we have included additional disclosure on page 36 of the Amended Registration Statement. Similarly, as a formal determination
of the value or treatment of the Company’s liabilities post-Business Combination has not been made, the unaudited pro forma condensed
combined statement of operations does not contain any pro-forma adjustment resulting from a determination that the Company’s warrants
should be equity classified or from a change in the value of the warrants as liabilities.

Adjustments to Unaudited Pro Forma Condensed Combined Statement
of Operations, page 36

 15. It is not clear how the $5.6
                                            million in Adjustment 2 corresponds to the $6.7 million in Adjustment 4 to the Pro Forma
                                            Combined Balance Sheet discussed on page 36. Please revise your disclosures as necessary.

In response to the Staff’s comment,
we have revised the disclosure on page 36 of the Amended Registration Statement.

U.S. Securities and Exchange Commission

Division of Corporation Finance

July 5, 2022

Page 5

Net Income (Loss) per Share, page 37

 16. Please expand your disclosure
                                            to explain how the 12,864,702 shares was calculated. Also disclose the number of shares that
                                            are anti-dilutive and not included in the diluted shares outstanding by type.

In response to the Staff’s comment,
we have revised the disclosure on page 37 of the Amended Registration Statement.

Risk Factors

Bull Horn’s shareholders will experience
dilution due to the issuance of Company Common Stock to the Coeptis stockholders..., page 41

 17. Please revise to disclose
                                            all possible sources and extent of dilution that shareholders who elect not to redeem their
                                            shares may experience in connection with the business combination. Provide disclosure of
                                            the impact of each significant source of dilution, including the amount of equity held by

United States securities and exchange commission logo
June 22, 2022
Robert Striar
Chief Executive Officer
Bull Horn Holdings Corp.
801 S. Pointe Drive, Suite TH-1
Miami Beach, Florida 33139
Re:Bull Horn Holdings Corp.
Registration Statement on Form S-4
Filed May 25, 2022
File No. 333-265206
Dear Mr. Striar:
            We have reviewed your 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 amending your registration statement and providing the
requested information.  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 registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form S-4 filed May 25, 2022
Frequently Used Terms, page iii
1.Please delete any terms that are not used in the registration statement, such as the defined
term "Coeptis warrants," or revise as appropriate.
Anticipated Accounting Treatment, page 8
2.Your disclosures on page 8 regarding the planned accounting treatment do not appear
consistent with those disclosed on page 29.  Specifically on page 8 you indicate that the
transaction will be accounted for as a business combination and any excess of the
purchase price over the fair value of net assets and other identifiable intangible assets
acquired will be recorded as goodwill.  Please revise your disclosures as necessary.

 FirstName LastNameRobert Striar
 Comapany NameBull Horn Holdings Corp.
 June 22, 2022 Page 2
 FirstName LastNameRobert Striar
Bull Horn Holdings Corp.
June 22, 2022
Page 2
Interests of the Sponsor, Directors and Officers in the Business Combination, page 8
3.Please quantify here and in other relevant sections of the registration statement the
aggregate dollar amount of what the sponsor and its affiliates have at risk that depends on
completion of a business combination.  Please ensure that the aggregate amount you
disclose includes the current value of securities held, loans extended, fees due, and out-of-
pocket expenses for which the sponsor and its affiliates are awaiting reimbursement, if
any.  Provide similar disclosure for the company's officers and directors, if material.
Questions and Answers
Why am I receiving this proxy statement/prospectus?, page 13
4.We note your disclosure on page 7 that "[t]he presence, in person virtually or by proxy, of
Bull Horn shareholders representing at least 50% of the ordinary shares issued and
outstanding on the Record Date and entitled to vote on the Proposals to be considered at
the Shareholders Meeting will constitute a quorum for the Shareholders Meeting."
However, on page 14, you note that "[t]he presence, in person virtually or by proxy, of
Bull Horn shareholders representing a majority of the issued and outstanding ordinary
shares on the Record Date and entitled to vote on the Proposals to be considered at the
Shareholders Meeting will constitute a quorum for the Shareholders Meeting."  Please
reconcile.
What equity stake will current Bull Horn shareholders and Coeptis stockholders hold..., page 18
5.Please include footnotes to the table provided to disclose the number of shares associated
with Bull Horn warrants and Coeptis warrants and convertible debt to be outstanding at
the completion of the Business Combination.  Confirm to us that the shares included in the
table will be issued and outstanding at the completion of the Business Combination.
May the sponsor, Bull Horn's directors, officers, advisors or their affiliates purchase shares in
connection with the Business Combination?, page 24
6.We note your disclosure that "[p]ursuant to the Insider Letter Agreement, the sponsor has
agreed to waive its Redemption Rights with respect to the founder shares and any public
shares purchased during or after the IPO in connection with the consummation of the
Business Combination."  Please describe any consideration provided in exchange for this
agreement.
Unaudited Pro Forma Condensed Combined Financial Information, page 28
7.Please expand your disclosures to include all the material terms of the transaction,
including quantification of the Merger Consideration based on the facts and circumstances
presently known for each component, the number of new shares of Bull Horn common
stock to be issued to Coeptis stockholders and to be issued to Coeptis warrantholders, and
the number of new shares of Bull Horn common stock the Permitted Debt is convertible

 FirstName LastNameRobert Striar
 Comapany NameBull Horn Holdings Corp.
 June 22, 2022 Page 3
 FirstName LastNameRobert Striar
Bull Horn Holdings Corp.
June 22, 2022
Page 3
into.  Also disclose that all other outstanding equity instruments of Coeptis will be
terminated/cancelled without compensation, if correct.  Please confirm that the
outstanding unpaid transaction expenses and transaction bonuses have been reflected in
the pro forma financial information.
8.We note your disclosures regarding the merger, including on page 3, indicate that certain
issued and outstanding warrants to acquire shares of Coeptis stock will be assumed by
Bull Horn and converted into a warrant for shares of Bull Horn common stock.  Please
address what consideration was given to reflecting these warrants in the pro forma
financial information.
9.We note your disclosures on page 1 indicate that the sponsor agreed to lend Bull Horn
$66,667 per month, or up to $400,000, to deposit into the trust account in connection with
the extension of Bull Horn’s termination date from May 3, 2022 to November 3, 2022.
Please address what consideration was given to reflecting this loan in the pro forma
financial information.
10.Please address what consideration was given to reflecting the impact of the Domestication
transaction in the pro forma financial information.
11.We note your disclosures on page F-68 indicating that Coeptis entered into an agreement
with Statera Biopharma, Inc. for the acquisition by Coeptis of Statera’s toll-like receptor 5
(TLR5) agonist platform for $6 million.  Please address what consideration you gave to
reflecting this transaction in your pro forma financial information pursuant to Rule 11-
01(a) of Regulation S-X.
Adjustments to Unaudited Pro Forma Condensed Combined Balance Sheets, page 36
12.It appears that the $32,738 adjustment to additional paid-in capital is part of Adjustment
(3) rather than (2).  Please advise or revise as necessary.
13.For adjustment (4) related to the payment of estimated legal, financial advisory and other
professional fees, we note the adjustment to cash and cash equivalents, prepaid expenses
and other current expenses and deferred underwriting fee payable.  It would appear that
there should also be an adjustment to accumulated deficit.  Please advise or revise as
necessary.
14.For adjustment (6), please provide all of the disclosures required by Rule 11-02
(a)(11)(ii)(B) of Regulation S-X regarding your incomplete accounting.  Tell us your
consideration for disclosing any corresponding impact to the pro forma statement of
operations related to the change in fair value of warrants.
Adjustments to Unaudited Pro Forma Condensed Combined Statement of Operations, page 36
15.It is not clear how the $5.6 million in Adjustment 2 corresponds to the $6.7 million in
Adjustment 4 to the Pro Forma Combined Balance Sheet discussed on page 36.  Please
revise your disclosures as necessary.

 FirstName LastNameRobert Striar
 Comapany NameBull Horn Holdings Corp.
 June 22, 2022 Page 4
 FirstName LastName
Robert Striar
Bull Horn Holdings Corp.
June 22, 2022
Page 4
Net Income (Loss) per Share, page 37
16.Please expand your disclosure to explain how the 12,864,702 shares was calculated.  Also
disclose the number of shares that are anti-dilutive and not included in the diluted shares
outstanding by type.
Risk Factors
Bull Horn's shareholders will experience dilution due to the issuance of Company Common
Stock to the Coeptis stockholders..., page 41
17.Please revise to disclose all possible sources and extent of dilution that shareholders who
elect not to redeem their shares may experience in connection with the business
combination.  Provide disclosure of the impact of each significant source of dilution,
including the amount of equity held by founders, convertible securities, including warrants
retained by redeeming shareholders, at each of the redemption levels detailed in your
sensitivity analysis, including any needed assumptions.
The Certificate of Incorporation will designate a state or federal court located within the State of
Delaware as the exclusive forum..., page 52
18.We note that the Amended and Restated Certificate of Incorporation will provide that,
unless the company consents to the selection of an alternative forum, the federal district
courts of the United States of America shall, to the fullest extent permitted by law, be the
sole and exclusive forum for the resolution of any complaint asserting a cause of action
arising under the Securities Act.  Please disclose that there is uncertainty as to whether a
court would enforce such a provision.  Please also state that investors cannot waive
compliance with the federal securities laws and the rules and regulations thereunder.  In
that regard, we note that Section 22 of the Securities Act creates concurrent jurisdiction
for federal and state courts over all suits brought to enforce any duty or liability created by
the Securities Act or the rules and regulations thereunder.  Additionally, please revise to
note that this provision may also make it more costly for a shareholder to bring a claim
against you.
Your unexpired warrants may be redeemed prior to their exercise at a time that is
disadvantageous to you..., page 57
19.Please highlight the material risks to public warrant holders, including those arising from
differences between private and public warrants.  Clarify whether recent common stock
trading prices exceed the threshold that would allow the company to redeem public
warrants.  Clearly explain the steps, if any, the company will take to notify all
shareholders, including beneficial owners, regarding when the warrants become eligible
for redemption.

 FirstName LastNameRobert Striar
 Comapany NameBull Horn Holdings Corp.
 June 22, 2022 Page 5
 FirstName LastName
Robert Striar
Bull Horn Holdings Corp.
June 22, 2022
Page 5
Competition in the biotechnology and pharmaceutical industries may result in competing
products..., page 64
20.We note your disclosure that "[y]our current clinical trials may be insufficient to
demonstrate that [y]our potential products will be active, safe, or effective."  Please revise
to specify which clinical trials you are referring to.
Closing Conditions, page 95
21.We note your disclosure that a condition to closing the Business Combination is the
approval of the Bull Horn common stock for listing on Nasdaq, subject to official notice
of issuance.  Please disclose which Nasdaq market tier you intend to list on and whether
this condition to closing could be waived without recirculation or resolicitation.  Also,
please advise us as to the Nasdaq listing standard that you intend to qualify for, the status
of your listing process and whether it appears at this time that you meet the listing
standard.
Interests of Bull Horn's Directors and Officers and Others in the Business Combination, page 97
22.It appears that the deferred underwriting fees remain constant and are not adjusted based
on redemptions.  Revise your disclosure to disclose the effective underwriting fee on a
percentage basis for shares at each redemption level presented in your sensitivity analysis
related to dilution.
Background of the Business Combination, page 99
23.Please disclose whether the sponsor and management have a track record with SPACs.  If
so, please provide balanced disclosure about this record and the outcomes of prior
transactions.
24.We note your disclosure that from May 2021 through July 2021, you negotiated with
Company B, "a company with a portfolio of professional team assets" and that over the
course of "three months, [you] worked to finalize the portfolio of assets and process for
taking said assets into a public structure."  Please clarify whether these assets relate to
professional sports franchises.  Please also clarify if communications with Company B
ceased after three months and if so, why.
25.Please provide further detail regarding the business of Company C.  Please also clarify
how the market conditions were different in March of 2022 as compared to April of 2022
when you signed the merger agreement with Coeptis.
26.Please explain why the transaction with Company D was abandoned.
27.Please disclose any discussions about continuing employment or involvement for any
persons affiliated with Bull Horn Holdings Sponsor LLC before the Business
Combination and any formal commitment to retain JonesTrading after the Business
Combination.

 FirstName LastNameRobert Striar
 Comapany NameBull Horn Holdings Corp.
 June 22, 2022 Page 6
 FirstName LastNameRobert Striar
Bull Horn Holdings Corp.
June 22, 2022
Page 6
28.Please provide further detail regarding your process for identifying a target company to
enter into a business combination with.  For example, please explain how and why your
search shifted from entertainment, media and sports companies to Coeptis and indicate
whether you evaluated other companies in the life sciences industry.
29.We note your disclosure that on March 8, 2022, the Bull Horn Board had a call to discuss
terminating negotiations with a target.  Please clarify which target you terminated
negotiations with at this time and why.
Description of Negotiation Process with Coeptis, page 100
30.Please revise your disclosure to provide a materially complete description of the valuation
negotiations between Bull Horn and Coeptis.
Bull Horn Board's Reasons for the Approval of the Business Combination, page 102
31.Please disclose whether and how the Board took into account the consideration to be paid
for the transaction.  If the Board did not take this factor into account, please explain why.
Please also disclose the public market valuation of Coeptis at the time the merger
agreement was entered into, compare that valuation to the value of the merger
consideration being paid to acquire Coeptis, and discuss how the board viewed
any premium or discount to Coeptis' public market valuation and how that factored into
the Board's decision.
Engagement of Vantage Point, page 104
32.Please disclose the compensation paid or payable to Vantage Point.  Refer to Item
1015(b)(4) of Regulation M-A.  Please ensure that your disclosure includes the fees
Vantage Point will receive upon completion of the business combination and any amount
that is contingent upon completion of the business combination.
Opinion of Vantage Point, page 105
33.We note your disclosure that Vantage Point’s Opinion to the Bull Horn Board stated in
part that the Business Combination is fair, from a financial point of view, to Bull Horn.
Please include cautionary language noting, if true, that the fairness opinion addresses the
fairness to all shareholders of Bull Horn as a group as opposed to only those shareholders
of Bull Horn unaffiliated with the sponsor or its affiliates.
Valuation Approaches/Methodologies Used, page 106
34.We note the disclosure on page 178 that Coeptis' ownership interests in the Vy-Gen Bio
products represents a 50% ownership interest in such technologies, with the ownership
interest in the therapeutic product scalable down to 20% under certain circumstances and
with the ownership interest in the diagnostic product scalable down to 25%.  Please
expand the disclosure in this section to address how

CORRESP
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IMPERIAL
CAPITAL, LLC

10100 Santa Monica Boulevard, Suite 2400

Los Angeles, California 90067

October 26, 2020

VIA EDGAR

Amy Geddes and Jim Allegretto

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Bull Horn Holdings Corp.

    Registration Statement on Form S-1

    Filed September 21, 2020, as amended

    File No. 333-248940

Dear Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations under
the Securities Act of 1933, as amended (the “Act”), the undersigned, for itself and the other several underwriters,
hereby joins in the request of Bull Horn Holdings Corp. that the effective date of the above-referenced Registration Statement
be accelerated so as to permit it to become effective at 5:00 p.m. Eastern time on Tuesday, October 27, 2020, or as soon thereafter
as practicable.

Pursuant to Rule 460 of the General Rules and Regulations under
the Act, the undersigned advises that approximately 200 copies of the Preliminary Prospectus dated October 13, 2020 are expected
to be distributed to prospective underwriters and dealers, institutional investors, retail investors and others.

The undersigned advises that it has complied and will continue
to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

* * *

[Signature Page Follows]

    Very truly yours,

    Imperial capital, llc

    By:
    /s/ Chris Shepard

    Name:
    Chris Shepard

    Title:
    Executive Vice President

    As Representative of the several underwriters

[Signature Page to Underwriter’s Acceleration Request
Letter]

CORRESP
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filename1.htm

Bull Horn Holdings Corp.

801 S. Pointe Drive, Suite TH-1

Miami Beach, Florida 33139

VIA EDGAR

October 26, 2020

U.S. Securities & Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, NE

Washington, D.C. 20549

Attn: Ms. Amy Geddes

 Re: Amendment No. 3 to Registration Statement on Form
S-1

Filed October 22, 2020

File No. 333-248940

Dear Ms. Geddes:

Bull Horn Holdings Corp.
(the “Company,” “we,” “our” or “us”) hereby transmits
the Company’s response to the comment letter received from the staff (the “Staff”) of the U.S. Securities
and Exchange Commission (the “Commission”) on October 22, 2020 regarding Amendment No. 3 to the Company’s
Registration Statement on Form S-1 filed with the Commission on October 22, 2020. For the Staff’s convenience, we have repeated
below the Staff’s comment in bold, and have followed the Staff’s comment with the Company’s response. Disclosure
changes made in response to the Staff’s comments have been made in the Company’s Amendment No. 4 to its Registration
Statement on Form S-1 (the “Registration Statement”), which is being filed with the Commission contemporaneously
with the submission of this letter.

Amendment No. 3 to Form S-1 filed October
22, 2020

General

 1. Please tell us when you negotiated the terms relating to the potential purchase by institutional
investors of up to 9.9% of the units in the offering. Please also clarify the purpose for issuing membership interests in the sponsor
in connection with this purchase, as well as whether each institutional investor may purchase up to a maximum of 9.9% of the units
in the offering, or whether 9.9% if the cumulative total for all institutional investors. If it is the former, please disclose
the total number of institutional investors that have indicated their interest in purchasing in the offering, and the total percent
of the offering they will purchase if each purchases 9.9%. Please also file your agreement with the institutional investors, or
tell us why you do not believe you are required to do so.

Further to our discussion
with the Staff on October 23, 2020, the Staff is advised as follows:

 1. There are a total of six institutional investors (with two of such investors technically managing
two accounts each) who are parties to the referenced subscription agreements with the Company’s sponsor. Pursuant to the
subscription agreements, the investors will each purchase interests in the Company’s sponsor (and not the Company itself)
entitling them to an allocation of anchor investor shares.

    Ms. Amy Geddes

October 26, 2020

Page 2 of 2

 2. The Company was separately introduced to each of these investors beginning on or about October
12, 2020 by the Company’s investment bankers, and the Company’s discussions with each investor were undertaken privately
and separately.

 3. The Company’s investment bankers have confirmed that all of the investors are “qualified
institutional buyers” (as defined in Rule 144A under the Securities Act of 1933, as amended) with whom such investment bankers
have pre-existing relationships.

 4. The subscription agreements provide that each investor has indicated an interest in purchasing
up to 9.9% of the units in the public offering, which would (if all of the those indications of interest become confirmed orders)
equate to 59.4% of the units being offered by the Company in the offering. As already disclosed in the Registration Statement,
the investors have only provided an indication of interest and are not legally bound to purchase units in the offering.

 5. As disclosed in Amendment No. 3 to the Registration Statement, the subscription agreements were
entered into “in consideration” of the investors providing an indication of interest in buying units in the offering.
This consideration was offered to these investors given their status as potential anchor investors in the Company, which distinguishes
them from other investors.

 6. With respect to the issue of filing the subscription as an exhibit to Amendment No. 4, after discussions
with the Staff, the Company has elected to file the form of subscription agreement as an exhibit. Together with the disclosures
in Amendment No. 4 of the material terms and purpose of the agreements, as well as certain cautionary disclosures related to these
matters, we believe that all investors in the offering have access to all material information regarding this matter.

With the foregoing
taken into consideration, and in response to the Staff’s comment, we have updated the disclosures on the cover page to the
prospectus and on pages 10, 19, 68, 88, 90 and 91 of the prospectus included in Amendment No. 4 to the Registration Statement
to more clearly articulate the matters raised by the Staff, including notably the number of investors, the aggregate percentage
of units they could possibly purchase in the offering and the risks associated with such purchases if they should occur. The Staff
is advised that as the arrangements only relate to indications of interest, and thus the disclosure in the Registration Statement
is framed as an “up to” maximum amount of potential anchor investor shares, should any of the investors not confirm
their order following effectiveness of the Registration Statement, the Company will modify its disclosure on these matters in the
final prospectus for the offering, as well as including final disclosure based on confirmed orders generally.

We thank the Staff for
its review of the foregoing and the Registration Statement. If you have further comments, please feel free to contact to our counsel,
Stuart Neuhauser, at sneuhauser@egsllp.com, or Lawrence A. Rosenbloom, at lrosenbloom@egsllp.com, or by telephone at (212)
370-1300.

Sincerely,

/s/ Robert Striar

Robert Striar,
Chief Executive Officer

Bull Horn Holdings
Corp.

CORRESP
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Bull Horn Holdings Corp.

801 S. Pointe Drive, Suite TH-1

Miami Beach, Florida 33139

October 26, 2020

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, N.E.

Mail Stop 3030

Washington, D.C. 20549

Attention: Amy Geddes

    Re:
    Bull Horn Holdings Corp.

    Registration Statement on Form S-1, as amended

    Filed September 21, 2020

    File No. 333-248940

Dear Ms. Geddes:

Pursuant to Rule 461
under the Securities Act of 1933, as amended, Bull Horn Holdings Corp. hereby requests acceleration of effectiveness of the above
referenced Registration Statement so that it will become effective at 5:00 p.m. EST on October 27, 2020, or as soon as thereafter
practicable.

    Very truly yours,

    /s/ Robert Striar

    Robert Striar

    Chief Executive Officer

    cc:
    Ellenoff Grossman & Schole LLP

    White & Case LLP

United States securities and exchange commission logo
October 22, 2020
Robert Striar
Chief Executive Officer
Bull Horn Holdings Corp.
801 S. Pointe Drive, Suite TH-1
Miami Beach, Florida 33139
Re:Bull Horn Holdings Corp.
Amendment No. 3 to Registration Statement on Form S-1
Filed October 22, 2020
File No. 333-248940
Dear Mr. Striar:
            We have reviewed your amended 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 amending your registration statement and providing the
requested information.  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 registration statement and the information you
provide in response to these comments, we may have additional comments.
Amendment No. 3 to Form S-1 filed October 22, 2020
General
1.Please tell us when you negotiated the terms relating to the potential purchase by
institutional investors of up to 9.9% of the units in the offering.  Please also clarify the
purpose for issuing membership interests in the sponsor in connection with this purchase,
as well as whether each institutional investor may purchase up to a maximum of 9.9% of
the units in the offering, or whether 9.9% if the cumulative total for all institutional
investors.  If it is the former, please disclose the total number of institutional investors that
have indicated their interest in purchasing in the offering, and the total percent of the
offering they will purchase if each purchases 9.9%.  Please also file your agreement with
the institutional investors, or tell us why you do not believe you are required to do so.

 FirstName LastNameRobert Striar
 Comapany NameBull Horn Holdings Corp.
 October 22, 2020 Page 2
 FirstName LastName
Robert Striar
Bull Horn Holdings Corp.
October 22, 2020
Page 2
            You may contact Amy Geddes at 202-551-3304 or Jim Allegretto at 202-551-3849 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Scott Anderegg at 202-551-3342 or Erin Jaskot at 202-551-3442 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

CORRESP
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Bull Horn Holdings Corp.

801 S. Pointe Drive, Suite TH-1

Miami Beach, Florida 33139

October 15, 2020

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, N.E.

Mail Stop 3030

Washington, D.C. 20549

Attention: Amy Geddes

    Re:
    Bull Horn Holdings Corp.

    Registration Statement on Form S-1, as amended

    Filed September 21, 2020

    File No. 333-248940

Dear Ms. Geddes:

On October 13,
2020, Bull Horn Holdings Corp. (the “Company”) requested acceleration of the effective date of the above-referenced
Registration Statement so that it would become effective at 4:00 p.m. (New York time) on October 15, 2020, or as soon thereafter
as practicable. The Company hereby withdraws such request.

    Very truly yours,

    /s/ Robert Striar

    Robert Striar

    Chief Executive Officer

    cc:
    Ellenoff Grossman & Schole LLP

    White & Case LLP

CORRESP
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IMPERIAL
CAPITAL, LLC

10100 Santa Monica Boulevard, Suite 2400

Los Angeles, California 90067

October 15, 2020

VIA EDGAR

Amy Geddes and Jim Allegretto

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Bull Horn Holdings Corp.

    Registration Statement on Form S-1

    Filed September 21, 2020, as amended

    File No. 333-248940

Dear Ladies and Gentlemen:

On October 13, 2020, the undersigned, for
itself and the several underwriters, joined in the request of Bull Horn Holdings Corp. (the “Company”) to accelerate
the effective date of the above-referenced Registration Statement so as to permit it to become effective at 4:00 p.m., Eastern
Standard Time, on October 15, 2020, or as soon thereafter as practicable.

        The
undersigned, for itself and the several underwriters, hereby joins in the Company’s withdrawal of such request.

* * *

[Signature Page Follows]

    Very truly yours,

    Imperial capital, llc

    By:
    /s/ Chris Shepard

    Name: Chris
Shepard

    Title: Executive
Vice President

    As Representative
of the several underwriters

CORRESP
1
filename1.htm

IMPERIAL
CAPITAL, LLC

10100 Santa Monica Boulevard, Suite 2400

Los Angeles, California 90067

October 13, 2020

VIA EDGAR

Amy Geddes and Jim Allegretto

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

 Re: Bull Horn Holdings Corp.

Registration Statement on Form S-1

Filed September 21, 2020, as amended

File No. 333-248940

Dear Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations under
the Securities Act of 1933, as amended (the “Act”), the undersigned, for itself and the other several underwriters,
hereby joins in the request of Bull Horn Holdings Corp. that the effective date of the above-referenced Registration Statement
be accelerated so as to permit it to become effective at 4:00 p.m. Eastern time on Thursday, October 15, 2020, or as soon thereafter
as practicable.

Pursuant to Rule 460 of the General Rules and Regulations under
the Act, the undersigned advises that approximately 200 copies of the Preliminary Prospectus dated October 13, 2020 are expected
to be distributed to prospective underwriters and dealers, institutional investors, retail investors and others.

The undersigned advises that it has complied and will continue
to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

* * *

[Signature Page Follows]

    Very truly yours,

    Imperial capital, llc

    By:
    /s/ Chris Shepard

    Name:
    Chris Shepard

    Title:
    Executive Vice President

    As Representative of the several underwriters

[Signature Page to Underwriter’s
Acceleration Request Letter]

CORRESP
1
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Bull Horn Holdings Corp.

801 S. Pointe Drive, Suite TH-1

Miami Beach, Florida 33139

October 13, 2020

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, N.E.

Mail Stop 3030

Washington, D.C. 20549

Attention: Amy Geddes

    Re:
    Bull Horn Holdings Corp.

    Registration Statement on Form S-1, as amended

    Filed September 21, 2020

    File No. 333-248940

Dear Ms. Geddes:

Pursuant to Rule 461
under the Securities Act of 1933, as amended, Bull Horn Holdings Corp. hereby requests acceleration of effectiveness of the above
referenced Registration Statement so that it will become effective at 4:00 p.m. EST on October 15, 2020, or as soon as thereafter
practicable.

    Very truly yours,

    /s/ Robert Striar

    Robert Striar

    Chief Executive Officer

    cc:

    Ellenoff Grossman & Schole LLP

    White & Case LLP

CORRESP
1
filename1.htm

Bull
Horn Holdings Corp.

801
S. Pointe Drive, Suite TH-1

Miami
Beach, Florida 33139

VIA
EDGAR

October
9, 2020

U.S.
Securities & Exchange Commission

Division
of Corporation Finance

Office
of Trade &Services

100
F Street, NE

Washington,
D.C. 20549

Attn:
Ms. Amy Geddes

    Re:

    Bull
        Horn Holdings Corp.

        Registration
        Statement on Form S-1

        Filed
        September 21, 2020

        File
        No. 333-248940

Dear
Ms. Geddes,

Bull
Horn Holdings Corp. (the “Company” or “we”) hereby transmits the Company’s response
to the comment letter received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission,
dated October 5, 2020 regarding the Company’s Registration Statement on Form S-1 filed on September 21, 2020 (the “Registration
Statement”). For the Staff’s convenience, we have repeated below the Staff’s comments in bold, and have
followed each comment with the Company’s response.

Form
S-1 filed September 21, 2020

Summary
Financial Data, page 18

 1. Refer
                                         to our previous comment 1. It does not appear you have considered “Actual”
                                         balances in your calculation of “As Adjusted” balances as of June 30, 2020.
                                         For example, you state deferred underwriting commissions are $2,250,000, which would
                                         calculate an “As Adjusted” balance in liabilities of $2,414,106, in consideration
                                         of both the “Actual” liabilities balance at June 30, 2020 of $164,106 and
                                         the deferred underwriting commissions of $2,250,000 associated with this offering. Please
                                         revise all “As Adjusted” figures to consider the “Actual” June
                                         30, 2020 balances as well as the items associated with this offering or explain in detail
                                         why such figures should not be reflected in the “As Adjusted” column.

Response:
We have revised our disclosure to clarify the calculation of the “As Adjusted” Working Capital and “As Adjusted”
Total Assets.

 2. Refer
                                         to our previous comment 4. The adjustment to assets and working capital of $15,245 is
                                         not appropriate as it is already considered in the “Actual” June 30, 2020
                                         figures. Please revise.

Response:
We have revised our disclosure to clarify the calculation of the “As Adjusted” Working Capital and “As Adjusted”
Total Assets.

 3. Refer
                                         to our previous comment 1. Your footnote (1) indicates the “As Adjusted”
                                         figures include the $3 million in proceeds you expect to receive from the sale of the
                                         private placement warrants, but the figures as presented in the table do not appear to
                                         reflect such proceeds. Please revise or advise.

Response:
We have revised our disclosure to clarify the calculation of the “As Adjusted” Working Capital and “As Adjusted”
Total Assets.

Ms.
Amy Geddes

October
9, 2020

Page
2 of 2

 4. Refer
                                         to our previous comment 2. Please revise your disclosure to specifically state, if true
                                         that net proceeds of $76 million reflects subtraction of the underwriting discount of
                                         $1.5 million and offering expenses of $0.5 million.

Response:
We have revised our disclosure to clarify the calculation of the “As Adjusted” Working Capital and “As Adjusted”
Total Assets.

We
thank the Staff for its review of the foregoing and the Registration Statement. If you have further comments, please feel free
to contact to our counsel, Stuart Neuhauser, at sneuhauser@egsllp.com or by telephone at (212) 370-1300.

    Sincerely,

    /s/
    Robert Striar

    Robert
        Striar, Chief Executive Officer

        Bull
        Horn Holdings Corp.

    cc:
    Stuart Neuhauser, Esq.

United States securities and exchange commission logo
October 5, 2020
Robert Striar
Chief Executive Officer
Bull Horn Holdings Corp.
801 S. Pointe Drive, Suite TH-1
Miami Beach, Florida 33139
Re:Bull Horn Holdings Corp.
Registration Statement on Form S-1
Filed September 21, 2020
File No. 333-248940
Dear Mr. Striar:
            We have reviewed your 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 amending your registration statement and providing the
requested information.  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 registration statement and the information you
provide in response to these comments, we may have additional comments.
Form S-1 filed September 21, 2020
Summary Financial Data, page 18
1.Refer to our previous comment 1. It does not appear you have considered "Actual"
balances in your calculation of "As Adjusted" balances as of June 30, 2020. For example,
you state deferred underwriting commissions are $2,250,000, which would calculate an
"As Adjusted" balance in liabilities of $2,414,106, in consideration of both the "Actual"
liabilities balance at June 30, 2020 of $164,106 and the deferred underwriting
commissions of $2,250,000 associated with this offering. Please revise all "As Adjusted"
figures to consider the "Actual" June 30, 2020 balances as well as the items associated
with this offering or explain in detail why such figures should not be reflected in the "As
Adjusted" column.

 FirstName LastNameRobert Striar
 Comapany NameBull Horn Holdings Corp.
 October 5, 2020 Page 2
 FirstName LastName
Robert Striar
Bull Horn Holdings Corp.
October 5, 2020
Page 2
2.Refer to our previous comment 4. The adjustment to assets and working capital of
$15,245 is not appropriate as it is already considered in the "Actual" June 30, 2020
figures. Please revise.
3.Refer to our previous comment 1. Your footnote (1) indicates the "As Adjusted" figures
include the $3 million in proceeds you expect to receive from the sale of the private
placement warrants, but the figures as presented in the table do not appear to reflect
such proceeds.  Please revise or advise.
4.Refer to our previous comment 2. Please revise your disclosure to specifically state, if
true that net proceeds of $76 million reflects subtraction of the underwriting discount of
$1.5 million and offering expenses of $0.5 million.
            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.
            You may contact Amy Geddes at 202-551-3304 or Jim Allegretto at 202-551-3849 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Scott Anderegg at 202-551-3342 or Jennifer Lopez-Molina at 202-551-3792 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

CORRESP
1
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Bull Horn Holdings Corp.

801 S. Pointe Drive, Suite TH-1

Miami Beach, Florida 33139

VIA EDGAR

September 21, 2020

U.S. Securities & Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, NE

Washington, D.C. 20549

Attn: Ms. Amy Geddes

Re:  Bull
                                         Horn Holdings Corp.

    Amendment No. 3 to Draft Registration
                                         Statement on Form S-1

    Submitted August 21, 2020

CIK No. 0001759186

Dear Ms. Geddes:

Bull Horn Holdings Corp.
(the “Company,” “we,” “our” or “us”) hereby transmits
the Company’s response to the comment letter received from the staff (the “Staff”) of the U.S. Securities
and Exchange Commission (the “Commission”), on September 10, 2020, regarding the Amendment No. 3 to Draft Registration
Statement on Form S-1 submitted to the Commission on August 21, 2020.

For the Staff’s convenience,
we have repeated below the Staff’s comments in bold, and have followed each comment with the Company’s response. Disclosure
changes made in response to the Staff’s comments have been made in the Company’s live filed Registration Statement
on Form S-1 (the “Registration Statement”), which is being filed with the Commission contemporaneously with
the submission of this letter.

Form S-1 DRS/A filed August 21, 2020

Summary Financial Data, page 17

 1. Your narrative descriptions in the footnotes to the table presented here indicate the “As
Adjusted” column considers actual shareholders' equity ($15,425), the unit offering ($75 million), private placement warrants
($3 million), cash held outside the trust account ($1 million), and deferred underwriting costs ($2.25 million). It appears the
“As Adjusted” column represents the aggregation of the adjustments as opposed to June 30, 2020 actual figures adjusted
to represent the impact of the offering. Please revise or advise.

Response: Management notes that the
footnotes to the table specifically state that the “as adjusted” calculation equals actual shareholders’
equity of $15,245 as of June 30, 2020, plus $75,000,000 in cash that will be held in trust from the proceeds of this offering and
the sale of the private warrants, plus $1,000,000 in cash held outside the trust accounts, less $2,250,000 of deferred underwriting
commissions. Management notes that by stating the “as adjusted” equals the sum of these amounts, the reader can recalculate
the amount disclosed in the table, as noted below:

 Ms. Amy Geddes

September 21, 2020

Page 2 of 2

    Cash to be held in trust from proceeds of offering and sale of private warrants
      75,000,000

    Cash held outside trust account
      1,000,000

    Deferred underwriting commission
      (2,250,000 )

    Actual Shareholders' Equity at June 30, 2020
      15,245

    Total Working Capital
      73,765,245

 2. It appears that your narrative identifies that working capital and net assets include $1 million
held outside the trust and $3 million in private placement notes, but does not indicate that it also includes the underwriting
discount and offering expenses, aggregating $2 million. Please revise this discussion to either state that it includes net proceeds
of $76 million or include disclosure that the underwriting discount of $1.5 million and offering expenses of $0.5 million are considered
in this calculation.

Response: Management notes that the
Company discloses that working capital includes the $75,000,000 of cash to be held in the trust account plus $1,000,000 of cash
to be held outside of the trust account (for an aggregate of $76,000,000). Such amount is net of the offering expenses and underwriting
discounts paid. Since the offering expenses and underwriting discounts are considered paid, they would not be available for working
capital purposes and, therefore, would not be included in the calculation of working capital.

 3. Please also revise your disclosure to specify that the $1 million held outside the trust is
included in the gross proceeds of the unit offering and private placement warrants.

Response: Management has revised
its disclosure as requested by the Staff.

 4. Finally, please support the inclusion of the June 30, 2020 equity balance of $15,245 in the
As Adjusted working capital and total asset balances as of June 30, 2020.

Response: Management included such
amount as it represents the historical activity of the Company and would not be eliminated upon the closing of the offering. Since
such amount is historical and actual in nature, it would be reflected in the ongoing operations and results of the Company and,
therefore, should be included in the As Adjusted presentation.

We thank the Staff for
its review of the foregoing and the Registration Statement. If you have further comments, please feel free to contact to our counsel,
Stuart Neuhauser, at sneuhauser@egsllp.com or by telephone at (212) 370-1300.

    Sincerely,

    /s/ Robert Striar

    Robert Striar,
Chief Executive Officer
Bull Horn Holdings
Corp.

cc:
Stuart Neuhauser, Esq.

United States securities and exchange commission logo
September 10, 2020
Robert Striar
Chief Executive Officer
Bull Horn Holdings Corp.
801 S. Pointe Drive, Suite TH-1
Miami Beach, Florida 33139
Re:Bull Horn Holdings Corp.
Amendment No. 3 to Draft Registration Statement on Form S-1
Submitted August 21, 2020
CIK No. 0001759186
Dear Mr. Striar:
            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 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 registration statement, we may have additional
comments.
Form S-1 DRS/A filed August 21, 2020
Summary Financial Data, page 17
1.Your narrative descriptions in the footnotes to the table presented here indicate the "As
Adjusted" column considers actual shareholders' equity ($15,425), the unit offering ($75
million), private placement warrants ($3 million), cash held outside the trust account ($1
million), and deferred underwriting costs ($2.25 million). It appears the "As Adjusted"
column represents the aggregation of the adjustments as opposed to June 30, 2020 actual
figures adjusted to represent the impact of the offering. Please revise or advise.
2.It appears that your narrative identifies that working capital and net assets include $1
million held outside the trust and $3 million in private placement notes, but does not
indicate that it also includes the underwriting discount and offering expenses, aggregating

 FirstName LastNameRobert Striar
 Comapany NameBull Horn Holdings Corp.
 September 10, 2020 Page 2
 FirstName LastName
Robert Striar
Bull Horn Holdings Corp.
September 10, 2020
Page 2
$2 million. Please revise this discussion to either state that it includes net proceeds of $76
million or include disclosure that the underwriting discount of $1.5 million and offering
expenses of $0.5 million are considered in this calculation.
3.Please also revise your disclosure to specify that the $1 million held outside the trust is
included in the gross proceeds of the unit offering and private placement warrants.
4.Finally, please support the inclusion of the June 30, 2020 equity balance of $15,245 in the
As Adjusted working capital and total asset balances as of June 30, 2020.
            You may contact Amy Geddes at 202-551-3304 or Jim Allegretto at 202-551-3849 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Scott Anderegg at 202-551-3342 or Jennifer Lopez-Molina at 202-551-3792 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services