September 20, 2019

Berge Abajian
Principal Financial Officer
Bergio International, Inc.
12 Daniel Road E.
Fairfield, NJ 07004

       Re: Bergio International, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed August 21, 2019
           File No. 000-54714

Dear Mr. Abajian:

       We have limited our review of your filing to the financial statements
and related
disclosures 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 10-K for the Fiscal Year Ended December 31, 2018

Item 8. Financial Statements and Supplementary Data
Report of Independent Registered Public Accounting Firm, page F-1

1.     We note that your independent auditor only provided an audit opinion for
the year ended
       December 31, 2018. Please amend your filing to provide audit opinions
covering all
       periods of audited financial statements required to be presented in this
form, i.e. the two
       years ended December 31, 2018. Refer to Note 2(a) to Rule 8-01 of
Regulation S-X and
       Rule 8-02 of Regulation S-X.
Item 15. Exhibits and Financial Statement Schedules, page 34

2.     It appears your Form 10-K is incorporated by reference into previously
filed Form S-8
       filings. Please amend your filing to provide a consent from your auditor
related to the use
       of their audit report. Such consent is required due to incorporation by
reference of the
       Form 10-K into the previously filed registration statements. Refer to
Item 601 of
 Berge Abajian
Bergio International, Inc.
September 20, 2019
Page 2
         Regulation S-K. Alternatively, tell us why you believe a consent is
not necessary.
       In closing, 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 Robert Babula, Staff Accountant at (202) 551-3339 or
Andrew Blume,
Staff Accountant at (202) 551-3254 with any questions.



FirstName LastNameBerge Abajian                               Sincerely,
Comapany NameBergio International, Inc.
                                                              Division of
Corporation Finance
September 20, 2019 Page 2                                     Office of
Consumer Products
FirstName LastName