United States securities and exchange commission logo





                               July 27, 2022

       Aneil Manhas
       Chief Executive Officer
       Bruush Oral Care Inc.
       30 Wellington Street West, 5th Floor
       Toronto, ON M5L 1E2
       Canada

                                                        Re: Bruush Oral Care
Inc.
                                                            Amendment No. 3 to
Registration Statement on Form F-1
                                                            Filed July 26, 2022
                                                            File No. 333-265969

       Dear Mr. Manhas:

              We have reviewed your 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.

       Amendment No. 3 to Registration Statement on Form F-1

       Capitalization, page 21

   1.                                                   Please refer to prior
comment 4. As previously requested and as described in the notes to
                                                        the table, revise the
capitalization table to include a separate line item to reflect the
                                                        warrant derivative
liabilities in your actual historical and pro forma as adjusted financial
                                                        information.
 Aneil Manhas
FirstName
Bruush OralLastNameAneil Manhas
            Care Inc.
Comapany
July       NameBruush Oral Care Inc.
     27, 2022
July 27,
Page  2 2022 Page 2
FirstName LastName
Dilution, page 25

2.       We note that dilution per share to new investors in this offering
should represent the
         difference between the assumed initial public offering price per share
of $6.20 and the pro
         forma as adjusted net tangible book value per share of ($0.28). Please
revise to reflect this
         amount as ($6.48).
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Tracey Houser at 202-551-3736 or Kevin Kuhar at
202-551-3662 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Dillon Hagius at 202-551-7967 or Christopher Edwards at 202-551-6761
with any other
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Life
Sciences
cc:      Lahdan S. Rahmati