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                           November 14, 2022

       Timothy G. Dixon
       President and Chief Executive Officer
       Therapeutic Solutions International, Inc.
       701 Wild Rose Lane
       Elk City , Idaho 83525

                                                        Re: Therapeutic
Solutions International, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed October 31,
2022
                                                            File No. 333-268070

       Dear Timothy G. Dixon:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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 October 31, 2022

       Cover Page

   1.                                                   Please amend your
filing to name GHS Investments, LLC as an underwriter and selling
                                                        shareholder. At a
minimum, this disclosure should appear to the prospectus cover page
                                                        and in the plan of
distribution. For guidance, refer to Securities Act Compliance and
                                                        Disclosure
Interpretation 139.13.
 Timothy G. Dixon
FirstName
TherapeuticLastNameTimothy    G. Dixon
            Solutions International, Inc.
Comapany 14,
November   NameTherapeutic
               2022          Solutions International, Inc.
November
Page 2     14, 2022 Page 2
FirstName LastName
2.       We note your statement on the cover page that the selling stockholders
may offer the
         shares of your common stock for resale in the over-the-counter market,
in isolated
         transactions, or in a combination of such methods of sale, and that
the selling stockholders
         will sell their shares at prevailing market prices or privately
negotiated prices. We also
         note the disclosure on page 4 and on the back cover that the offering
price will be at a
         20% discount to the market price. Finally, we note your statement on
page 4: "We may
         offer these securities in amounts, at prices and on terms determined
at the time of offering.
         The securities may be sold directly to you, through agents, or through
underwriters and
         dealers." Please revise to address these inconsistencies or clarify.
Prospectus Summary
The Offering, page 4

3.       We note that Section 1(u) of the Purchase Agreement defines "Purchase
Price" as "80% of
         the lowest trading price of the Common Stock during the Valuation
Period." We also note
         that following such time that the Company's common stock is listed on
a National
         Exchange, the purchase price will be "90% of the lowest VWAP during
the Valuation
         Period, subject to a floor of $[ ] . . ." Please clearly disclose here
how you will determine
         the full discount price at which GHS Investments, LLC will receive the
shares.
4.       Please revise to disclose the material terms of the agreement with GHS
Investments, LLC,
         including the material conditions under which the company may access
the funds
         available under it and the term of the agreement (we note you refer to
the Purchase
         Agreement with GHS Investments, LLC as the "PA" and on page 48 say
that a CSPA
         (undefined) terminates on September 19, 2024). Please additionally
disclose the material
         market activities of GHS Investments, LLC, including any short selling
of the company   s
         securities or other hedging activities that GHS Investments, LLC may
or has engaged in,
         including prior to entering into the agreement and prior to the
receipt of any shares
         pursuant to the terms of the agreement, how it intends to distribute
the securities it owns
         or will acquire, and how the provisions of Regulation M may prohibit
it and any other
         distribution participants that are participating in the distribution
of the company   s
         securities from (i) engaging in market making activities (e.g.,
placing bids or making
         purchases to stabilize the price of the common stock) while the equity
line is in effect and
         (ii) purchasing shares in the open market while the equity line is in
effect.
 Timothy G. Dixon
FirstName
TherapeuticLastNameTimothy    G. Dixon
            Solutions International, Inc.
Comapany 14,
November   NameTherapeutic
               2022          Solutions International, Inc.
November
Page 3     14, 2022 Page 3
FirstName LastName
Risk Factors, page 16

5.       Please disclose the material risks of an investment in the company and
in the offering,
         including the dilutive effect of the formula or pricing mechanism on
the company   s share
         price, the possibility that the company may not have access to the
full amount available to
         it under the equity line and how any sales activities after
announcement of a put including
         short selling may negatively affect the company   s share price. Also
consider the
         applicability of the following risk factor on page 19: "This Offering
is being placed on a
            best efforts    basis and we may not raise the entire $10,000,000"
relating to an offering
         of Restricted Shares and Units.
Selling Stockholders, page 43

6.       Please revise to provide the information required by Item 507 of
Regulation S-K. Refer to
         Item 7 of Form S-1.
General

7.       You disclose that you are registering the resale of an indeterminate
number of shares of
         your common stock that will be sold to GHS Investments, LLC under a
Purchase
         Agreement dated September 19, 2022. Per the securities Purchase
Agreement, you may
         sell up to $10,000,000 shares of common stock over the duration of the
agreement. Please
         note that you must disclose the number of common stock shares being
registered on this
         registration statement. Please revise the prospectus cover page,
offering summary and
         selling stockholder table to disclose the specific number of shares
being registered under
         the equity line agreement. Refer to Securities Act Sections Compliance
and Disclosure
         Interpretations Questions 139.13 and Item 501(b)(2) of Regulation S-K.
8.       We note that it appears you may have elected to incorporate
information by reference
         pursuant to General Instruction VII. If you are intending to
incorporate by reference
         please provide us with an analysis as to your eligibility to
incorporate by reference,
         specifically as it relates to General Instruction VII(D)(1)(c). In
this respect, we note your
         statement on page 21: "Our common stock is considered to be penny
stock under rules
         promulgated by the Securities and Exchange Commission (the    SEC
)." If you are not
         intending to incorporate by reference, please remove all references in
the registration
         statement to incorporating by reference and ensure all required
information is included in
         the registration statement. As an example, provide the information
required by Item 303 of
         Regulation S-K (Management's discussion and analysis of financial
condition and results
         of operation). We also note that filing your 10-K as Exhibit 13.2 does
not satisfy any of
         these requirements.
9.       Please refile your exhibits in the proper text-searchable format.
Please refer to
         Item 301 of Regulation S-T. Please also revise to provide the
information required by Item
         16(a) of Form S-1.
 Timothy G. Dixon
Therapeutic Solutions International, Inc.
November 14, 2022
Page 4


        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 Jordan Nimitz at 202-551-5831 or Margaret Schwartz at
202-551-7153
with any questions.



                                                           Sincerely,

FirstName LastNameTimothy G. Dixon                     Division of Corporation
Finance
                                                       Office of Industrial
Applications and
Comapany NameTherapeutic Solutions International, Inc.
                                                       Services
November 14, 2022 Page 4
cc:       Hugh Kelso, Esq.
FirstName LastName