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                         March 5, 2021

       Richard E. Davis
       Chief Financial Officer
       Arch Therapeutics, Inc.
       235 Walnut Street, Suite 6
       Framingham, MA 01702

                                                        Re: Arch Therapeutics,
Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed February 26,
2021
                                                            File No. 333-252588

       Dear Mr. Davis:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.

                                                        Please contact Abby
Adams at (202) 551-6902 with any questions.




                         Sincerely,


                         Division of Corporation Finance

                         Office of Life Sciences
       cc:                                              Park S. Bramhall, Esq.