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                             October 3, 2023

       Bannor Michael MacGregor
       Chief Executive Officer
       American Picture House Corp
       555 Madison Avenue 5FL
       New York, NY 10022

                                                        Re: American Picture
House Corp
                                                            Amendment No. 1 to
Registration Statement on Form 10-12G
                                                            Filed September 22,
2023
                                                            File No. 000-56586

       Dear Bannor Michael MacGregor:

                                                        We have reviewed your
filing and have the following comments.

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in
your response.

             After reviewing your response and any amendment you may file in
response to this letter,
       we may have additional comments.

       Amendment No. 1 to Registration Statement on Form 10-12G

       Risk Factors
       Risks Related to the Company's Common Shares, page 13

   1.                                                   We reissue comment 5.
Revise to include a risk factor discussing the different authorized
                                                        classes of stock,
including the nature of the disparate voting rights, number of votes per
                                                        share to which each
class is entitled and the potential dilution to common stock holders
                                                        upon conversion of the
Series A preferred stock.
 Bannor Michael MacGregor
FirstName  LastNameBannor
American Picture House CorpMichael MacGregor
Comapany
October    NameAmerican Picture House Corp
        3, 2023
October
Page 2 3, 2023 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Three Months Ended June 30, 2023 Compared to Three Months Ended June 30, 2022
General and Administrative Expenses, page 19

2.       Please revise your discussion in MD&A to explain the circumstances
that resulted in your
         determination that the collection of $193,932 from a customer is
uncertain or improbable,
         consistent with your response to comment 7.
Board of Directors, page 31

3.       We note your revised disclosure in response to comment 9 and reissue
our comment.
         Revise to specifically identify each director that is independent
under the independence
         standards applicable to you. Refer to Item 407(a)(1) of Regulation
S-K. In this regard,
         we note that you have only identified the independent directors on
each committee, but
         you have not clearly identified all independent directors on the board
as a whole.
Executive Compensation, page 32

4.       We note your revised disclosure in response to comment 10 and reissue
our comment.
         Revise to include the disclosure required by Item 402(m)-(r) of
Regulation S-K for the
         fiscal year ended December 31, 2022. In this regard, it appears you
have only described
         the compensation payable in fiscal year 2023. Also ensure that your
disclosure includes
         the tables and narrative disclosure required by Regulation S-K. To the
extent no
         compensation was paid to directors or officers in 2022, so state.
Statement of Operations for the Six Months Ended June 30, 2023, page 44

5.       We note that you restated your statements of operations in response to
comment 15.
         Please identify the financial statements as    restated    and provide
the disclosures required
         under ASC 250-10-50 with respect to the correction of an error, as
applicable.
Report of Independent Registered Public Accounting Firm, page 55

6.       We reissue comment 14 in part, since you continue to provide two audit
reports on pages
         42 and 55 of your filing. Please remove one of these audit reports and
ensure that the
         audit report provided is properly dated. Also, in light of your
restatement in response to
         comment 15, please obtain an audit report that includes an explanatory
paragraph stating
         that the previously issued financial statements have been restated for
the correction of a
         error and makes reference to the disclosure of the correction of the
error in the notes to the
         financial statements. Refer to paragraphs 9-10 and 16-17 of AS 2820.
 Bannor Michael MacGregor
FirstName  LastNameBannor
American Picture House CorpMichael MacGregor
Comapany
October    NameAmerican Picture House Corp
        3, 2023
October
Page 3 3, 2023 Page 3
FirstName LastName
Notes to the Financial Statements for the Years Ending December 31, 2022 and
2021
Note 2 - Summary of Significant Accounting Policies, page 60

7.       We note your response to comment 17 but are unable to locate the
disclosures referenced
         in your response. Please tell us where you provided your accounting
policy for stock-
         based compensation as previously requested in comment 17.
Produced and Licensed Content Costs, page 61

8.       Please revise the disclosure you provided in response to comment 19 to
identify the
         caption in the income statement where the amortization of production
costs is recorded.
Assigned Rights to the Feature Film, Buffaloed, page 64

9.       Please revise the disclosures you provided in response to comment 18
to quantify the fair
         value of the assets acquired and the consideration incurred under the
arrangement. To the
         extent the consideration is contingent, also disclose if and how such
consideration
         is remeasured.
Revenues and Costs from Services and Products, page 64

10.      The disclosure you provided in response to comment 22 appears to only
describe your
         revenue recognition policy for consulting services. Please revise this
disclosure to also
         describe how you account for revenues from licensing and distribution
of film and other
         entertainment rights.
11.      We reissue comment 23 as you did not appear to address it. Where you
state that    a
         majority of the consulting services were performed by management and
members of the
         Board of Directors with no separate compensation due or payable to
these individuals,
         describe if and how you measure and allocate their labor to the cost
of revenues.
Note 6 - Equity, page 68

12.      Please revise your disclosure to quantify the liquidation preference
as previously
         requested under comment 25.
 Bannor Michael MacGregor
FirstName  LastNameBannor
American Picture House CorpMichael MacGregor
Comapany
October    NameAmerican Picture House Corp
        3, 2023
October
Page 4 3, 2023 Page 4
FirstName LastName
        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.

        Please contact Keira Nakada at 202-551-3659 if you have questions
regarding comments
on the financial statements and related matters. Please contact Taylor Beech at
202-551-4515 or
Jennifer Lopez Molina at 202-551-3792 with any other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Trade &
Services
cc:      Gary L. Blum, Esq.