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                              April 27, 2023

       David Koos
       Chief Executive Officer
       Regen BioPharma, Inc.
       4700 Spring Street, Suite 304
       La Mesa, CA 91942

                                                        Re: Regen BioPharma,
Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed April 13,
2023
                                                            File No. 333-271234

       Dear David Koos:

              We have limited our review of your registration statement to
those issues we have
       addressed in our comments. In some of our comments, we may ask you to
provide us with
       information so we may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply 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 registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form S-1 Filed April 13, 2023

       Prospectus Summary
       About Us, page 4

   1.                                                   We note the following
disclosure:

                                                              for
HemaXellerate:    Once re-infused into the patient, the patient   s bone marrow
is
                                                            regenerated and
begins to function normally;
                                                              for dCellVax:
By inhibiting this enzyme in these dendritic cells, the patient   s cells
                                                            can now attack
cancers, particularly breast cancer;
                                                              for tCellVax:
Immune cells are removed from the patient, treated with siRNA to
                                                            inhibit NR2F6 and
the cells re-infused to the patient. Now that the inhibitor protein
                                                            is blocked, the
immune system is very activated and kills tumors;
 David Koos
Regen BioPharma, Inc.
April 27, 2023
Page 2
             for DiffronC:    This drug uses our proprietary siRNA in vivo to
inhibit cancer growth
           and activate T cells;    and
             for DuraCar:    DuraCar is comprised of CAR-T cells which have
been treated with
           an shRNA targeting the gene NR2F6. By inhibiting NR2F6, we expect
our DuraCar
           cells to have greater efficacy and persistence than conventional
CAR-T cells   .

      Please revise these and any similar statements throughout your prospectus
to eliminate
      any predictions of efficacy as these statements appear to be premature
given that clinical
      trials on your product candidates have not commenced and revise to
eliminate any
      conclusions of efficacy as efficacy determinations are solely within the
authority of the
      FDA.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

      You may contact Doris Stacey Gama at 202-551-3188 or Tim Buchmiller at
202-551-
3635 with any other questions.



                                                            Sincerely,
FirstName LastNameDavid Koos
                                                            Division of
Corporation Finance
Comapany NameRegen BioPharma, Inc.
                                                            Office of Life
Sciences
April 27, 2023 Page 2
cc:       William Aul, Esq.
FirstName LastName