Panamera Healthcare Corporation

4270 Orchard Hill Drive

Edmond, OK 73025

VIA EDGAR

November 24, 2014

Stacie Gorman

Senior Counsel

US Securities and Exchange Commission

Division of Corporation Finance

100 F Street NE

Washington, DC 20549

Re: Panamera Healthcare Corporation

Registration Statement on Form S-1

Filed September 26, 2014

File No. 333-198977

Dear Ms. Gorman:

This letter is in response to your comment letter dated October 23, 2014, with regard to the Form S-1 filing of Panamera Healthcare Corporation, a Nevada corporation ("Panamera Healthcare" or the "Company") filed on September 26, 2014. Responses to each comment have been keyed to your comment letter.

General

1. Please provide us with support for all quantitative and qualitative business and industry data used in the registration statement, pertaining to your discussion of the healthcare industry, including data culled from Medical Group Management Association and the World Bank. Clearly mark the specific language in the supporting materials that supports each statement. The requested information should be filed as EDGAR correspondence or, alternatively, should be sent in paper form accompanied by a cover letter indicating that the material is being provided pursuant to Securities Act Rule 418 and that such material should be returned to the registrant upon completion of the review process. In addition, please confirm to us that any third party data included in the registration statement was not prepared for or commissioned by the registrant or its affiliates.

We hereby confirm that third party data included in our registration statement was not prepared for or commissioned by us or our affiliates. The data we present in our registration statement derived from publications of the World Bank and the Medical Group Management Association (MGMA). The specific sources of such information are as follows:

World Bank Health Statistics

References to health expenditure per capita (current US$)

Total health expenditure is the sum of public and private health expenditures as a ratio of total population. It covers the provision of health services (preventive and curative), family planning activities, nutrition activities, and emergency aid designated for health but does not include provision of water and sanitation. Data are in current U.S. dollars.

References to health expenditure per capita (current US$) in the registration statement are accessible to the public on the following web site:

● http://data.worldbank.org/indicator/SH.XPD.PCAP/countries

We provide herewith the data downloaded from the above web site as follows:

The following chart is Condensed from http://data.worldbank.org/indicator/SH.XPD.PCAP/countries

The specific data relating to expenditure per capita in the United States are specifically $8,895.12 (highlighted in yellow) while that of the United Kingdom, to which we contrast the United States, is highlighted in blue, specifically $3,647.47. Our assertion that U.S. per capita expenditures exceed that of many developed countries by 100%, including the United Kingdom is supported by this data from the World Bank. Other developed countries that meet these criteria although not specifically mentioned in our registration statement are Belgium, Finland, and New Zealand.

France (highlighted in orange), cited in our registration statement in a context other than per capita expenditure less than 50% of that of the United States spends $4,690.

The accompanying Excel file name with highlighted fields is: sh.xpd.totl.zs_Indicator_en_excel_v2.xls

References to health expenditure, total (% of GDP)

Total health expenditure is the sum of public and private health expenditure. It covers the provision of health services (preventive and curative), family planning activities, nutrition activities, and emergency aid designated for health but does not include provision of water and sanitation.

● http://data.worldbank.org/indicator/SH.XPD.TOTL.ZS

We cite this file as our source for United States expenditure for healthcare as 17.90% of GDP, in 2012:

We amend the section of our Registration Statement, Our Market, to clearly reference each page of the World Bank website where the information is accessible to the public.

Qualitative Information derived from Medical Group Management Association

We amend the section of our Registration Statement, Our Market, to update the results of the MGMA survey to the more recent 2104 survey as reported in the July issue of MGMA's monthly journal, "MGMA Connection" and submit the relevant sections of the journal in paper form pursuant to Securities Act Rule 418, as an exhibit 1 to this letter (starting on page 10).

Clarification has been added to our Registration Statement that the qualitative information from the MGMA study is available in the July 2014 issue of "MGMA Connection."

2. Please supplementally provide us with copies of all written communications, as defined in Rule 405 under the Securities Act, that you or anyone authorized to do so on your behalf, present to potential investors in reliance on Section 5(d) of the Securities Act, whether or not they retain copies of the communications.

None.

3. Please provide us with copies of any graphics, maps, photographs, and related captions or other artwork including logos that you intend to use in the prospectus. Such graphics and pictorial representations should not be included in any preliminary prospectus distributed to prospective investors prior to our review.

None.

Registration Statement Cover Page

4. Please revise your cover page to clarify that your securities will be offered on a continuous basis under Rule 415.

The cover page has been revised accordingly.

Prospectus Cover Page

5. Please revise to provide all of the disclosure required by Item 501(b)(8)(iii) of Regulation S-K.

This disclosure has been added.

Table of Contents, page 2

6. Please revise your disclosure in the last paragraph hereunder to clarify that the prospectus will be updated to the extent required by law.

This disclosure has been updated.

Prospectus Summary

Panamera Healthcare Corporation

Our Services, page 3

7. Please revise the summary to discuss briefly your historical and current operations, including the development of your consulting and marketing model. Please discuss in greater detail how the company will earn fees from providing consulting and management services, including a more robust discussion of the payment structure of your contractual arrangements. Refer to Item 503(a) of Regulation S-K.

This disclosure has been revised.

8. Please revise to better explain industry-specific "turnaround strategies" and "value-based care" so prospective investors will have clearer insight on the range of services you provide.

This disclosure has been revised.

Risk Factors

Risks Relating to Our Business and Industry

General

9. Please revise to include a risk factor to make clear, if true, that management does not have any public company experience.

A risk factor has been added.

We have reported limited consulting…, page 7

10. Please revise the risk factor narrative under this subheading and elsewhere in this section to more accurately capture your specific risks. Please also review your risk factors and eliminate those generic risks applicable to any public company or revise accordingly to more pointedly address your business. As another example, we note your general discussion of unfavorable general economic conditions on page 8 and again on page 13 in this section.

· We have reivsed our risk factors.

We deleted the following 2 risk factors from or original S-1:

·	We will incur ongoing costs and expenses for SEC reporting and compliance and we may not be able to remain in compliance, making it difficult for investors to sell their shares, if at all.

·	Our status as an "emerging growth company" under the JOBS Act of 2012 may make it more difficult to raise capital as and when we need it.

Risks Related to Our Common Stock, page 10

Our current management can exert significant influence…, page 11

11. Please revise the subcaption to clarify your board's ability to cause you to engage in a business combination without seeking shareholder approval. Additionally, please expand this risk factor and the subcaption, as appropriate, to clarify that your directors will exercise complete control over the company and have the ability to make decisions regarding, (i) whether to issue common stock and preferred stock, including decisions to issue common and preferred stock to themselves; (ii) employment decisions, including their own compensation arrangements, and (iii) whether to enter into material transactions with related parties.

This risk factor has been revised.

Use of Proceeds, page 15

12. In light of the range of $15,000 - $55,000.00 to devote to your marketing efforts, please revise to discuss with greater specificity what you plan to accomplish based on these varying amounts.

This disclosure has been revised.

Selling Security Holders, page 18

13. Please provide the name(s) of the natural persons with voting or dispositive control over the company's securities held by PB Capital LC.

The managing members of PB Capital LC are Sterling Barton and Nanuk Warman, of which, Sterling Barton has dispositive control of securities held by PB Capital.

Management's Discussion and Analysis of Financial Condition and Results of Operations

Overview, page 19

14. Please revise to provide more detailed milestones including the anticipated time frame for beginning and completing each milestone.

This disclosure has been updated.

15. Please also fully describe the going concern opinion and how the concerns raised in the opinion impact your prospective business operations.

·	This disclosures has been updated

Revenue Recognition, page 19

16. Please expand your disclosure, both here and on page F-10, to describe how you determine that each of the stated criteria has been met.

·	This disclosure has been updated.

17. Related to the comment above, please expand your disclosure to describe how your service agreements are structured. For example, indicate whether you work on retainer, charge for hours incurred, or negotiate a set fee for specific services, etc.

This disclosure has been revised.

Liquidity and Capital Resources, page 20

18. Please discuss the company's specific cash requirements for next 12 months to continue its operations.

This disclosure has been updated.

Emerging Growth Company, page 22

19. We note that you intend to rely on certain exemptions available to emerging growth companies. Please discuss to what extent these and other exemptions are available to you as a smaller reporting company.

We have expanded our discussion of "Emerging Growth Company" and have made reference in this discussion to our related risk factor on page 13.

Business

Our Customers, page 24

20. In the business section, please discuss the material terms of the consulting agreements with MediLinc Resources, Inc. and Claims Link Inc.

This disclosure has been updated.

21. We note that each of your management services agreements allows for maximum monthly fees of $5,000. Please clarify what happens if billable hours exceed this limit in a given month.

This disclosure has been updated.

Management, page 26

Officers and Board of Directors, page 26

22. Please revise your disclosure in this section to discuss the extent of Mr. Summer's experience with providing consulting services to healthcare related clients. Please state examples of the types of services he has provided and specifically identify the markets in which he has provided such services.

This disclosure has been updated.

23. Please also briefly describe the specific experience, qualifications, attributes or skills that led to the conclusion that each named person should serve as a director. Refer to Item 401(e) of Regulation S-K.

This disclosure has been updated.

Certain Relationships and Related Party Transactions, page 32

24. We note your disclosure that Kratos Healthcare, Inc. has agreed to loan you up to $75,000 and your disclosure on page 8 that you will pay offering expenses using loans. Please disclose the terms of the loans, including the interest rate and repayment terms.

This disclosure has been updated.

Part II. Information Not Required In Prospectus, page 55

Item 15. Recent Sales of Unregistered Securities, page 55

25. Please revise to briefly describe all of the facts relied upon to make the 4(2) exemption available. We may have further comment based on your response. Refer to Item 701(d) of Regulation S-K.

This disclosure has been updated.

Item 16. Exhibits and Financial Statement Schedules, page 56

Exhibit 5.1 - Opinion of Parsons/Burnett/Bjordahl/Hume, LLP

26. Please refer to the opinion in subclause four. The language here regarding the issuance of certain shares appears inconsistent with the disclosure in the selling stockholder table and the description of unregistered transactions in the prospectus, which states that such shares have already been issued. Please advise or revise as appropriate to reconcile.

The exhibit 5.1 has been updated.

The Company acknowledges that: (1) it is responsible for the adequacy and accuracy of the disclosure in this letter and the filings referenced herein; (2) staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and (3) the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please contact me with any further comments or questions. The Company will file this letter on EDGAR correspondence. I would appreciate if you would send any further responses directly to me electronically (doug@kratoshealthcare.com). If the SEC has no further comments, we expect to file a request for acceleration of the effective date.

Thank you in advance for your courtesies.

Sincerely,

/s/ Curtis Summers

_____________________

Curtis Summers, President