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                            June 23, 2022

       Christine Sheehy
       Chief Financial Officer
       Coeptis Therapeutics Inc.
       105 Bradford Rd, Suite 420
       Wexford, Pennsylvania 15090

                                                        Re: Coeptis
Therapeutics Inc.
                                                            Form 10-K for the
Year Ended December 31, 2021
                                                            File No. 000-56194

       Dear Ms. Sheehy:

              We have reviewed your June 9, 2022 response to our comment letter
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 these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

             After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       May 27, 2022 letter.

       Form 10-K for the Year Ended December 31, 2021

       Note 3. License Right, page F-10

   1.                                                   Your disclosures
related to the agreements with VyGen-Bio, Inc. indicate that you entered
                                                        into the agreements to
jointly develop two Vy-Gen-Bio, Inc. product candidates; however
                                                        your response indicates
that only VyGen-Bio, Inc. would be undertaking development
                                                        efforts. Please help us
reconcile your disclosures to your response. Also tell us whether
                                                        the agreements require
you to pay for any or all of the R&D costs VyGen-Bio incurs to
                                                        continues its
development of the CD38 Assets and/or if you are required to make
                                                        payments to VyGen-Bio
when they reach any development or regulatory milestones.
   2.                                                   With regard to your
assessment of Criterion 1, we note your analysis focuses on your
                                                        R&D projects. As the
agreement is for the joint development and commercialization of
                                                        CD38 Assets, please
address your consideration of paragraphs 2.48 through 2.51 of the
                                                        AICPA Accounting and
Valuation Guide as it relates to the status of the CD38 Assets at
 Christine Sheehy
Coeptis Therapeutics Inc.
June 23, 2022
Page 2
         the time you entered into the agreements with VyGen-Bio. As part of
your response, tell
         us whether the purpose of the agreements was for you to develop your
own R&D projects
         for the CD38 Assets or as a continuation of the current R&D projects
already initiated
         by VyGen-Bio.
3.       Your response discusses multiple alternative uses including to pursue
FDA approval for
         the commercialization of the CD38 assets, to sell your rights to the
CD38 assets to a third
         party, and to sell the CD38 assets to a third party. Please address
the following:
             Help us understand which of these uses you intended to pursue at
the time of entering
              into the agreements.
             In regards to the sale of your rights to the CD38 assets or the
sale of the CD38 assets,
              tell us whether you have control over the ability to sell and
whether approvals are
              required from other parties.
             Your response indicates that you are in early
discovery/pre-clinical stages in regards
              to these assets. Provide us with more details regarding the
current development
              status of the CD38 assets and the progress towards approval in
the country/countries
              in which the CD38 assets are intended to be sold. Please help us
better understand
              your basis for anticipating economic benefit given the current
development status.
             It would appear that the lack of FDA approval would also impact
the economic
              benefit that would be realized from selling your rights or the
assets. Please tell us
              what consideration you gave to this in your analysis.
4.       With regard to your assessment of Criterion 2, we note your reference
to paragraph 3.22
         of the AICPA Accounting and Valuation Guide. This paragraph states in
part, "[t]he task
         force believes that studies for toxicity represent a contingency that
must be
         resolved before an alternative future use is reasonably expected to
occur. Unless the
         compound successfully completes the toxicity studies for the
indication for cancers, it will
         not be considered for use in treating any other disease." With
reference to Exhibit 2-1
         Phases of Development in the Pharmaceutical Industry in the AICPA
Accounting and
         Valuation Guide, please tell us which clinical stage the CD38 Assets
are in and whether
         they have completed the studies for toxicity. If the early development
phase of testing for
         the CD38 Assets has not been completed, help us understand how you
were able to
         conclude that there would still be economic benefit associated with
the CD38 Assets in
         the event of negative results and that you would be able to proceed
with clinical trials
         under other indications.
       You may contact Nudrat Salik at (202) 551-3692 or Tracey Houser at (202)
551-3736 if
you have any questions.



FirstName LastNameChristine Sheehy                             Sincerely,
Comapany NameCoeptis Therapeutics Inc.
June 23, 2022 Page 2                                           Division of
Corporation Finance
FirstName LastName                                             Office of Life
Sciences