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                          August 25, 2022

       Terrence W. Norchi, M.D.
       President and Chief Executive Officer
       Arch Therapeutics, Inc.
       235 Walnut St., Suite 6
       Framingham, MA 01702

                                                        Re: Arch Therapeutics,
Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed August 22,
2022
                                                            File No. 333-267004

       Dear Dr. Norchi:

              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 Margaret
Schwartz at 202-551-7153 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Life Sciences
       cc:                                              Alan Wovsaniker, Esq.