United States securities and exchange commission logo





                             November 16, 2021

       John Trainor
       President and Director
       SensaSure Technologies, Inc.
       505 Park Avenue 4th Floor
       New York, New York 10022

                                                        Re: SensaSure
Technologies, Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed November 3,
2021
                                                            File No. 333-260017

       Dear Mr. Trainor:

             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
October 29, 2021 letter.

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

       Prospectus Summary
       Company Overview, page 1

   1.                                                   We note your response
to our prior comment 3 and reissue the comment in part. We
                                                        continue to note your
statements on pages 1 and 2 as well as in the Business section
                                                        that you have a
"validated method" or "validated methodology" to collect, extract, detect
                                                        and identify
substances. Please revise your disclosure here to explain what you mean by
                                                        "validated method."
   2.                                                   We note your response
to our prior comment 6 and reissue the comment in part. We note
                                                        your disclosure here
and in the Business section in which you continue to make statements
 John Trainor
FirstName LastNameJohnInc.
                         Trainor
SensaSure Technologies,
Comapany 16,
November   NameSensaSure
              2021        Technologies, Inc.
November
Page 2    16, 2021 Page 2
FirstName LastName
         related to potential safety and efficacy, which are premature given
the stage of
         development of the company's device. For example:

                "The EB method can lead to improved overall detection
accuracy."
                "Our EB device is quicker to use and provides more predictable
sample collection
              times[...]."

         Conclusions regarding safety and efficacy are determinations that only
the FDA or a
         foreign government equivalent has the authority to make. Please revise
your disclosure
         throughout your document, including but not limited to the statements
noted above, to
         eliminate the implication that your device has been or will ultimately
be determined safe
         and/or effective or have demonstrated safety and/or efficacy for
purposes of approval by
         the FDA or comparable agency. Alternatively, we advise you that you
may present the
         objective data from pre-clinical and clinical studies and trials
without drawing a
         conclusion from the results.
Business
Our Products and Ongoing Development, page 80

3.       We note your response to our prior comment 11 and your revised
disclosure here
         describing your current and developing production and distribution
systems. Please revise
         your disclosure here to more clearly state how the production and
delivery system you are
         currently developing will function.
Studies and Clinical Trials, page 88

4.       We note your response to our prior comment 11 and reissue the comment
in part. Please
         identify any specific study, trial or pilot program that you will be
relying on to support
         your 510(k) application with the FDA referenced on page 66.
Facilities, page 97

5.       We note your response to our prior comment 16 and reissue the comment.
Please expand
         your discussion here to include a description of the general character
of all of your
         facilities, such as storage and office space, that you may currently
utilize or plan to utilize
         to operate your business. For example, provide the size of each of
your facilities, each of
         their productive capacities, if applicable, and comment on their
suitability for your current
         and planned operations. Refer to Item 102 of Regulation S-K.
       You may contact Gary Newberry at (202) 551-3761 or Lynn Dicker at (202)
551-3616 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Jessica Ansart at (202) 551-4511 or Celeste Murphy at (202) 551-3257
with any other
questions.
 John Trainor
SensaSure Technologies, Inc.
November 16, 2021
Page 3
                                            Sincerely,
FirstName LastNameJohn Trainor
                                            Division of Corporation Finance
Comapany NameSensaSure Technologies, Inc.
                                            Office of Life Sciences
November 16, 2021 Page 3
cc:       David Fleming
FirstName LastName