February 27, 2025

Bradley Burnam
Chief Executive Officer
Global Health Solutions, Inc.
250 N. Westlake Blvd.
Westlake Village, CA 91362

        Re: Global Health Solutions, Inc.
            Offering Statement on Form 1-A
            Filed January 31, 2025
            File No. 024-12562
Dear Bradley Burnam:

       We have reviewed your offering statement and have the following
comments.

       Please respond to this letter by amending your offering statement and
providing the
requested information. If you do not believe a comment applies 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 offering statement and the
information you
provide in response to this letter, we may have additional comments.

Offering Statement on Form 1-A
Summary
The Company, page 1

1.     Please provide the basis for your statement that Hexagen "has over
200,000 human
       applications." Please also clarify, if true, that your company has yet
to recognize any
       revenues from its products.
Use of Proceeds, page 18

2.     Please revise Use of Proceeds to disclose more specifically how proceeds
from this
       offering will be applied, identifying the specific products and/or
indications relating to
       the allocations for "research & development" and "marketing and sales."
With
       reference to your going concern disclosure in your financial statements,
please
       disclose how long you expect the proceeds from this offering to fund
your operations
       if you sell 100%, 75%, 50% or 25% of the total amount of shares offered.
 February 27, 2025
Page 2

Our Business, page 19

3.     Please revise this section, where appropriate, to disclose whether any
of your products
       are currently sold commercially through partnerships or out-licensing
arrangements.
       To the extent that Hexagen has received pre-market clearances but is not
currently
       available for commercial sale, please briefly describe the reasons why.
Please also
       revise to briefly describe your future business plan.
Hexagen, page 20

4.     Please revise to briefly explain the 510(k) clearance process and to
disclose when
       Hexagen received its 510(k) clearances.
5.     We note your disclosure that your combination powder product utilizing
Hexagen
       with animal collagen, known as "Flex," is pending FDA clearance for use
on
       advanced wounds and burns. Please revise to disclose the type of FDA
clearance you
       have sought for Flex and, to the extent known, when you expect to
receive a decision
       from the FDA. Please also describe the material terms of the license
agreement and
       file the agreement as an exhibit or otherwise advise. Refer to Item
17(6) of Part III of
       Form 1-A.
6.     We note that you reference "ongoing clinical trials" and "ongoing
clinical
       development efforts" on page 7, and on page 23 you state that during
2025, you plan
       to "complete phase 2 trials for [y]our eczema indications." Please
revise this section to
       clarify whether these trials will be evaluating Hexagen as a medical
device or as a
       pharmaceutical. Please also revise to disclose whether you have
submitted INDs for
       your planned trials and whether you are currently conducting any
clinical trials. To the
       extent you are currently conducting clinical trials, please briefly
describe the
       parameters of each trial, including the jurisdiction of the trial and
the indication being
       evaluated.
Thermostable Intranasal Vaccine, page 20

7.     We note your disclosure that you have partnered with IAVI.org on a live
intranasal
       vaccine candidate. Please revise to identify the indication(s) to be
targeted, and
       disclose the current clinical development status of this vaccine
candidate. Please also
       briefly describe the material terms of your partnership with IAVI and
file the
       agreement as an exhibit.
Government Regulation, page 21

8.     Please expand your disclosure to briefly describe the FDA regulations
that apply
       or may apply to your development of each of medical device, drug and/or
biologic
       product candidates.
Intellectual Property, page 21

9.     In relation to the company's material patents, please revise your
intellectual property
       disclosure to clearly describe on an individual or patent family basis
whether such
       patent is owned or licensed, the product candidate or technology to
which such patent
       relates, the expiration year of each patent and the jurisdiction,
including any foreign
       jurisdiction, of each material pending or issued patent.
 February 27, 2025
Page 3

Management's Discussion and Analysis of Financial Condition and Results of
Operation
Results of Operations, page 22

10.    You disclose that the increase in research and development expenses
during the 2024
       Interim Period primarily resulted from a $65,900 payment to your R&D
vendor for
       clinical trials. Please clarify in revised disclosure which clinical
trial(s) this payment
       was related to.
Directors and Executive Officers, page 23

11.    Please revise the rightmost column of the table on page 23 to disclose
the approximate
       average number of hours per week or month that your Chief Medical
Officer is
       anticipated to work. Refer to Item 10(a)(2) of Part II of Form 1-A.
Liquidity and Capital Resources, page 23

12.    You disclose in the notes to the financial statements that your cash and
cash
       equivalents are less than a year's worth of cash reserves as of June 30,
2024. Please
       expand your discussion here to include a description and evaluation of
your internal
       and external sources of liquidity (i.e. share purchase agreement with
GEM,
       Crowdfunding Campaign) and include a brief discussion of any material
unused
       sources of liquidity. If you have identified a material deficiency in
liquidity, indicate
       the course of action that you have taken or propose to take to remedy
the deficiency.
       Refer to Item 9(b) of Form 1-A.
13.    You noted that deferred revenue for the periods presented is
attributable to a license
       agreement for your FlexAM product. Please provide disclosure, where
appropriate in
       the filing, of the material terms under the agreement. In your
disclosure, also address
       the amount of funds received for each period presented and to date, as
well as your
       accounting treatment, specifically when the deferred revenues will be
recognized.
Plan of Operations, page 23

14.    We note your disclosure on page 6 indicating that the regulatory process
is lengthy,
       expensive, and inherently uncertain. As such, please remove the
statements in this
       section that you plan to submit for FDA drug registration for eczema
indications
       during 2027 and for the onychomycosis indication in 2028, as such
statements appear
       to assume the successful completion of clinical trials for these
indications.
Compensation, page 24

15.    In your next filing, please update your executive compensation table for
the fiscal year
       ended December 31, 2024. Refer to Item 11(a) of Part II of Form 1-A.
Also, in a
       footnote or otherwise, please disclose if your Chief Medical Officer is
not
       compensated for his service in this capacity.
Signatures, page 29

16.    Please revise your signature page to include the signatures of your
principal financial
       officer and principal accounting officer.
 February 27, 2025
Page 4
Consolidated Financial Statements (Unaudited), page F-6

17.    Regarding your unaudited interim financial statements, please provide
disclosure on
       whether in the opinion of management all adjustments necessary to make
the interim
       financial statements not misleading have been included. Refer to Part
F/S(b)(5)(iii) of
       Form 1-A.
2. Summary of Significant Accounting Policies, page F-7

18.    Please revise to disclose your research and development expense policy.
Refer to ASC
       730-10-50-1.
12. Subsequent Events, page F-12

19.    You noted that since July 2024, the Company granted 110,075 options
under the 2024
       Stock Option Plan. Please explain how you determined the fair value of
the common
       stock underlying these issuances. In addition, tell us the reasons for
any significant
       differences between that fair value and the $11.26 offering price.

        We will consider qualifying your offering statement at your request. If
a participant in
your offering is required to clear its compensation arrangements with FINRA,
please have
FINRA advise us that it has no objections to the compensation arrangements
prior to
qualification.

        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. We also remind you that, following qualification of
your Form 1-A,
Rule 257 of Regulation A requires you to file periodic and current reports,
including a Form
1-K which will be due within 120 calendar days after the end of the fiscal year
covered by the
report.

        Please contact Vanessa Robertson at 202-551-3649 or Sasha Parikh at
202-551-3627
if you have questions regarding comments on the financial statements and
related
matters. Please contact Lauren Hamill at 303-844-1008 or Alan Campbell at
202-551-4224
with any other questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Life
Sciences
cc:   Jeffrey S. Marks