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                       March 16, 2023

       Alan M. Brown
       President, CEO, CFO, and Director
       TOMBSTONE EXPLORATION CORP
       6529 E. Friess Drive
       Scottsdale, AZ 85254

                                                        Re: Tombstone
Exploration Corporation
                                                            Form 20-F for the
fiscal year ended December 31, 2021
                                                            Filed June 29, 2022
                                                            File No. 000-29922

       Dear Alan M. Brown:

               We issued comments to you on the above captioned filing on
February 22, 2023. As of
       the date of this letter, these comments remain outstanding and
unresolved. We expect you to
       provide a complete, substantive response to these comments by March 31.

               If you do not respond, we will, consistent with our obligations
under the federal securities
       laws, decide how we will seek to resolve material outstanding comments
and complete our
       review of your filing and your disclosure. Among other things, we may
decide to release
       publicly, through the agency's EDGAR system, all correspondence,
including this letter, relating
       to the review of your filings, consistent with the staff's decision to
publicly release comment and
       response letters relating to disclosure filings it has reviewed.

              Please direct any questions to George K. Schuler at 202-551-3718
if you have
       questions regarding the engineering comments or Craig Arakawa at at
202-551-3650 with any
       other questions.




                       Sincerely,


                       Division of Corporation Finance

                       Office of Energy & Transportation