United States securities and exchange commission logo May 16, 2023 Shawn Leon Chief Executive Officer ETHEMA HEALTH Corp 950 Evernia Street West Palm Beach, Florida 33401 Re: ETHEMA HEALTH Corp Offering Statement on Form 1-A Post Qualification Amendment No. 1 Filed May 4, 2023 File No. 024-12027 Dear Shawn Leon: This is to advise you that we do not intend to review your amendment. We will consider qualifying your offering statement at your request. If a participant in your offering is required to clear its compensation arrangements with FINRA, please have FINRA advise us that it has no objections to the compensation arrangements prior to qualification. 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 Jessica Ansart at 202-551-4511 with any questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services