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                               March 20, 2023

       Matthew Reid
       Chief Executive Officer
       APPlife Digital Solutions Inc.
       50 California St, #1500
       San Francisco, CA 94111

                                                        Re: APPlife Digital
Solutions Inc.
                                                            Amendment No. 2 to
Registration Statement on Form S-1
                                                            Filed March 6, 2023
                                                            File No. 333-269389

       Dear Matthew Reid:

             We have reviewed your amended registration 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 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.
Unless we note
       otherwise, our references to prior comments are to comments in our March
2, 2022 letter.

       Amendment No. 2 to Registration Statement on Form S-1

       Description of Business
       Product, page 20

   1.                                                   We note your response
to prior comment 2 and reissue it, in part. Please highlight the risk
                                                        that you may be liable
for any cybersecurity breach resulting in the loss of customer
                                                        assets.
   2.                                                   We note your response
to prior comment 3. Please include the information provided in
                                                        your response letter in
your filing. For example, disclose that you expect users to store
                                                        their important
documents and certificates in files and that your interface will be tailored
                                                        to cater to file
storage.
 Matthew Reid
APPlife Digital Solutions Inc.
March 20, 2023
Page 2
General

3.     We note your response to prior comment 4. Please include the information
provided in
       your response letter in your filing. For example, disclose that, while
Matt Reid is your
       only employee, you manage multiple independent contractor teams to
operate your U.S.
       based business and that 100% of your revenue comes from servicing U.S.
customers.
        Please contact Kyle Wiley, Staff Attorney, at (202) 344-5791 or Jan
Woo, Legal Branch
Chief, at (202) 551-3453 with any other questions.



                                                            Sincerely,
FirstName LastNameMatthew Reid
                                                            Division of
Corporation Finance
Comapany NameAPPlife Digital Solutions Inc.
                                                            Office of
Technology
March 20, 2023 Page 2
cc:       Chase Chandler
FirstName LastName