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                               July 7, 2023

       Aneil Manhas
       Chief Executive Officer
       Bruush Oral Care Inc.
       128 West Hastings Street, Unit 210
       Vancouver, British Columbia V6B 1G8
       Canada

                                                        Re: Bruush Oral Care
Inc.
                                                            Registration
Statement on Form F-1
                                                            Filed June 26, 2023
                                                            File No. 333-272942

       Dear Aneil Manhas:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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.

       Registration Statement on Form F-1 filed June 26, 2023

       Exhibits

   1.                                                   We refer to your filing
tee table filed as Exhibit 107 to your registration statement. Please
                                                        revise your filing fee
table to include separate entries for shares of common stock issuable
                                                        upon conversion of
convertible note and exercise of warrants and pursuant to the private
                                                        placement.
       General

   2.                                                   Given the nature of the
offering and size of the transaction relative to the number of
                                                        outstanding shares held
by non-affiliates as disclosed in the prospectus, it appears that the
                                                        transaction may be an
indirect primary offering. Please provide us with an analysis of
 Aneil Manhas
Bruush Oral Care Inc.
July 7, 2023
Page 2
      your basis for determining that it is appropriate to characterize the
transaction as a
      secondary offering under Securities Act Rule 415(a)(1)(i). For guidance,
please see
      Securities Act Rules Compliance and Disclosure Interpretations Question
612.09.
        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 Benjamin Richie at 202-551-7857 or Margaret Schwartz at
202-551-
7153 with any other questions.



                                                            Sincerely,

FirstName LastNameAneil Manhas                              Division of
Corporation Finance
                                                            Office of
Industrial Applications and
Comapany NameBruush Oral Care Inc.
                                                            Services
July 7, 2023 Page 2
cc:       Lahdan S. Rahmati
FirstName LastName