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                              December 14, 2022

       Alan M. Brown
       President, CEO, CFO, and Director
       TOMBSTONE EXPLORATION CORP
       6529 E. Friess Drive
       Scottsdale, AZ 85254

                                                        Re: Tombstone
Exploration Corporation
                                                            Form 20-F for the
fiscal year ended December 31, 2021
                                                            Filed June 29, 2022
                                                            File No. 000-29922

       Dear Alan M. Brown:

              We have reviewed your filing and have the following comments. In
some of our
       comments, we may ask you to provide us with information so we may better
understand your
       disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 20-F for the fiscal year ended December 31, 2021

       Risks Associated with Mining, page 5

   1.                                                   We note you reference
Industry Guide 7 in this section and elsewhere in your filing.
                                                        Please note that
Industry Guide 7 has been replaced by Section 1300 of Regulation S-K.
                                                        Please change your
references and make the appropriate changes in your filing to comply
                                                        with Section 1300 of
Regulation S-K.
       The Bonanza Project, page 11

   2.                                                   Summary disclosure
includes the disclosure of all properties, which includes both your
                                                        material and
non-material properties pursuant to Item 1303(a) of Regulation S-K. Please
                                                        revise this section of
your filing to include the required information under Item 1303(b) of
                                                        Regulation S-K for all
your properties and disclose how you determined which of your
                                                        properties are
material.
 Alan M. Brown
FirstName LastNameAlan   M. Brown
TOMBSTONE      EXPLORATION    CORP
Comapany14,
December  NameTOMBSTONE
              2022            EXPLORATION CORP
December
Page 2    14, 2022 Page 2
FirstName LastName
3.       We also note your individual property disclosure is incomplete. Please
modify your filing
         to provide complete individual property disclosure as required by Item
1304(b) of
         Regulation S-K.
4.       We note your disclosure of an estimated tonnage, grade and
metallurgical recovery for
         your dump/tails heap leach operation. Please disclose the source of
this information,
         comment on the accuracy of the estimate, and provide addition detail
in regards to
         volumetric calculations, sampling, and metallurgical testing. In
addition, please state
         whether this tonnage and grade estimate is a resource, reserve, or an
exploration target.
5.       We note you refer to an exploration target on your Bonanza Area Claim
Block with has
         defined 250-350k Oz Au target areas and a 1-1.5 MM Oz Au overall
potential. Please
         revise your disclosure to conform to the requirements of Item
1304(g)(5) of Regulation S-
         K.
6.       We note you disclose exploration of your property has revealed
significant gold and silver
         reserves, as described in your press release on April 15, 2020. Please
make the
         appropriate resource/reserve disclosure and provide a technical report
summary as
         required by Item 1302(b) of Regulation S-K.
Recent Developments on Operations, page 13

7.       We note your disclosure in this section of 500,000 tons of already
mined material, which
         has been tested to show upwards of 26,000     50,000 oz. of gold.
Please state whether this
         tonnage and grade estimate is a resource, reserve, or an exploration
target and provide
         additional detail in regards to volumetric calculations, sampling, and
metallurgical testing.
2021 updates, page 14

8.       Please report your annual production as required by Item 1303(b)(2)(i)
of Regulation S-
         K. This would include your tonnage and grade placed on the heap leach
pad, total
         quantity of dore with the contained or sales of gold and silver. In
addition, please explain
         why no revenues are reported when Metals Research/Metalor USA received
your dore
         material.
The Tombstone Project, page 20

9.       We note you report the highest sample results in this section. When
reporting the results
         of sampling and chemical analyses, please revise your disclosure to
address each of the
         following regarding mineralization of existing or potential economic
significance on your
         property:
             Disclose only weighted-average sample analyses associated with a
measured length
              or a substantial volume.
             Eliminate all analyses from    grab    or    dump    samples,
unless the sample is of a
              substantial and disclosed weight.
             Eliminate all disclosure of the highest or best values/grades of
sample sets, presenting
 Alan M. Brown
TOMBSTONE EXPLORATION CORP
December 14, 2022
Page 3
              balanced disclosure of the drill and sampling results
                Eliminate grades disclosed as    up to    or    as high as
or    ranging from.
                Eliminate statements containing grade and/or sample-width
ranges.
                Aggregated sample values from related locations should be
aggregated based on a
              weighted average of lengths of the samples.
                Generally, use tables to improve readability of sample and
drilling data.
                Soil samples may be disclosed as a weighted average value over
an area.
                Refrain from reporting single soil sample values.
                Convert all ppb quantities to ppm quantities for disclosure.
                Avoid optimistic descriptive adjectives such as high-grade or
ore-grade.

        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.

       You may contact George K. Schuler at 202-551-3718 if you have questions
regarding the
engineering comments or Craig Arakawa at at 202-551-3650 with any other
questions.



FirstName LastNameAlan M. Brown         Sincerely,
Comapany NameTOMBSTONE EXPLORATION CORP
                                        Division of Corporation Finance
December 14, 2022 Page 3                Office of Energy & Transportation
FirstName LastName