United States securities and exchange commission logo





                               September 9, 2020

       Mark Palumbo
       Chief Executive Officer
       CannAssist International Corp
       1548 Loch Ness Dr.
       Fallbrook, CA 92028

                                                        Re: CannAssist
International Corp
                                                            Offering Statement
on Form 1-A/A
                                                            Filed August 25,
2020
                                                            File No. 024-11272

       Dear Mr. Palumbo:

             We have reviewed your amended offering statement 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 this letter by amending your offering 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 offering statement and the
information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
[month, day, year] letter.

       Form 1-A/A filed August 25, 2020

       Risks Related to the Company, page 9

   1.                                                   We note your response
to our prior comment 2; however, it does not appear the additional
                                                        risk factor has been
added. In line with our previous comment, please amend your filing to
                                                        add a risk factor
highlighting the concentration of control and the conflicts of interest that
                                                        may arise between the
interests of Mr. and Mrs. Palumbo on the one hand and the
                                                        company's shareholders
on the other.
       Marketing and Sales Strategy, page 25

   2.                                                   We note the revised
disclosure provided in response to our prior comment 4. Please
                                                        further expand this
disclosure to explain to whom EME Ltd. and Kinetik Technologies
 Mark Palumbo
CannAssist International Corp
September 9, 2020
Page 2
      distribute the company's products. In addition, please provide further
detail regarding the
      company's targeting of non-cosmetics customers as a business strategy.
Exhibits

3.    We note the analysis provided in response to our prior comment 7. In
light of the fact that
      the company does not have contractual agreements in place to secure its
third party
      manufacturer, distributors, or supplier, please add a risk factor
highlighting the potential
      impact of the inability of any of these parties to fulfill purchase
orders on an as needed
      basis and whether or not sufficient replacements may be found in a timely
manner.
4.    We note your response to our prior comment 8 which states that counsel
believes the units
      should be treated in a similar fashion as shares of capital stock under
applicable state law
      such that an opinion that the units are "legally issued, fully paid and
non-assessable" is
      appropriate. Please provide an analysis supporting this conclusion.
       Please contact Laura Crotty at 202-551-7614 or Mary Beth Breslin at
202-551-3625 with
any questions.



                                                            Sincerely,
FirstName LastNameMark Palumbo
                                                            Division of
Corporation Finance
Comapany NameCannAssist International Corp
                                                            Office of Life
Sciences
September 9, 2020 Page 2
cc:       Jarvis J. Lagman
FirstName LastName