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July 11, 2017
Securities and Exchange Commission
Division of Corporate Finance
Washington, D. C. 20549
Attn: Martin James
Senior Assistant Chief Accountant
Office of Electronics and Machinery
Re: Therapeutic Solutions International, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2016 Filed June 7, 2017
File No. 000-54554
Dear Mr. James:
Please see our response below to your letter of July 5, 2017:
Form 10-K for the Fiscal Year Ended December 31, 2016
General
1.
We note that you have not filed all the reports required by Section 13(a) or 15(d) of the Securities Exchange Act of 1934. Please file your quarterly report on Form 10-Q for the period ended March 31, 2017.
Response: We filed our quarterly report on Form 10-Q for the period ended March 31, 2017 on July 5, 2017.
Item 7. Management’s Discussion and Analysis of Financial Condition and Results ofOperations, page 17
2.
We note that you discuss your results of operations in some instances in actual dollars and in other instances in rounded number of dollars, such as thousands as well as millions. To enhance an investor’s understanding, please revise this section in future filings to consistently discuss your results of operations using the same unit of dollars.
Response: Your comment is acknowledged and all future filings with a results of operations section will use the same unit of dollars in our discussion.
Report of Independent Registered Public Accounting Firm, page F-2
3.
We note that PLS CPA opined upon your consolidated financial position as of December 31, 2015 and 2014 and your results of operations and cash flows for the years then ended, even though you did not include financial statements as of and for the year ended December 31, 2014 in the filing. Please have your independent accountants revise their audit report in future filings to opine only on the financial statements included in the filings.
Response: Your comment is acknowledged. We will advise our independent accountants of your comment and all future filing will only opine to the financial statements included in the filing.
Sincerely,
/s/ Gerry B. Berg
Gerry B. Berg
Chief Financial Officer
Therapeutic Solutions International, Inc.
4093 Oceanside Blvd., Suite B. Oceanside, CA 92056