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                              February 24, 2023

       Thomas Meyer
       Chief Executive Officer
       Altamira Therapeutics Ltd.
       Clarendon House
       2 Church Street
       Hamilton HM 11
       Bermuda

                                                        Re: Altamira
Therapeutics Ltd.
                                                            Registration
Statement on Form F-1
                                                            Filed February 16,
2023
                                                            File No. 333-269823

       Dear Thomas Meyer:

              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.

       Registration Statement on Form F-1 Filed February 16, 2023

       General

   1.                                                   We note statements in
numerous places throughout the registration statement stating or
                                                        suggesting that your
OligoPhore and SemaPhore peptide polyplex platform
                                                        technology is "safe and
effective." By way of example only, please see the first graphic
                                                        preceding the Table of
Contents and pages 1, 11, 57, and 79. Similarly, your discussions
                                                        of various clinical
trials include statements that your product candidates are "safe and well
                                                        tolerated" or have a
"favorable safety profile," such as on pages 55-57 and 84, 88, and
                                                        89. Please remove all
statements throughout your registration statement that state or
                                                        imply your conclusions
regarding the safety or efficacy of your product candidates and
 Thomas Meyer
Altamira Therapeutics Ltd.
February 24, 2023
Page 2
      technologies, as these determinations are solely within the authority of
the FDA and
      comparable regulatory bodies. With respect to safety, we will not object
to statements that
      your product candidates are well-tolerated, if true, or that no serious
adverse events
      deemed to be study related were reported. You may also present a balanced
summary of
      objective pre-clinical and clinical data, including whether clinical
trials trial met primary
      and secondary endpoints, without including your conclusions related to
efficacy.
2.    With reference to the first page of graphics, please revise these
graphics to adhere to plain
      English principles or remove them. In this regard, we note that these
graphics include
      scientific and technical information without context and as such the
content is likely to be
      unfamiliar to the average investor. Refer to Question 101.02 of our
Securities Act Forms
      Compliance and Disclosure Interpretations for guidance.
3.    The pipeline table should graphically demonstrate the current status of
your product
      candidates as well as indicate the material stages you will need to
complete prior to
      regulatory approval and commercialization. In this regard:
          We note you have included five columns that all appear to relate to
pre-clinical
          development, which could inappropriately create the impression of
further candidate
          progress. The narrative discussion of your programs is a more
appropriate place to
          make distinctions regarding different segments within a particular
development
          phase. Please revise to combine such columns, and note that we will
not object to
          pre-clinical stage columns of equal width labeled as "Discovery"
and/or "IND-
          enabling."
          Also, please revise to add separate columns of equal width for each
of Phase 1, Phase
          2, and Phase 3 clinical testing.

        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.

       Please contact Lauren Hamill at 303-844-1008 or Joe McCann at
202-551-6262 with any
other questions.



                                                             Sincerely,
FirstName LastNameThomas Meyer
                                                             Division of
Corporation Finance
Comapany NameAltamira Therapeutics Ltd.
                                                             Office of Life
Sciences
February 24, 2023 Page 2
cc:       Alexander Dinur
FirstName LastName