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                              October 19, 2023

       Dante Picazo
       Chief Executive Officer
       Cannabis Bioscience International Holdings, Inc.
       6201 Bonhomme Road
       Suite 466S
       Houston, TX 77036

                                                        Re: Cannabis Bioscience
International Holdings, Inc.
                                                            Amendment No. 5 to
Registration Statement on Form S-1
                                                            Filed September 27,
2023
                                                            File No. 333-267039

       Dear Dante Picazo:

            We have reviewed your amended registration statement and have the
following
       comments.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.
Unless we note otherwise,
       any references to prior comments are to comments in our July 17, 2023
letter.

       Amendment No. 5 to Registration Statement on Form S-1, Filed September
27, 2023

       Description of Business
       Clinical Trial in Which We Will be the Sponsor, page 56

   1.                                                   Please identify the
Harvard Health Publishing article you refer to in this sub-section.
 Dante Picazo
FirstName LastNameDante   Picazo Holdings, Inc.
Cannabis Bioscience International
Comapany
October 19,NameCannabis
            2023          Bioscience International Holdings, Inc.
October
Page 2 19, 2023 Page 2
FirstName LastName
2.       We note your disclosure that "CBD derived from hemp containing less
than 0.3% of
         tetrahydrocannabinol...was legalized at the federal level by the
Agriculture Improvement
         Act of 2018 and its sale and use of CBD products containing less than
0.3% of THC is
         legal in all states except for 18, which restrict sale and use for
various reasons, including
         the age of the purchaser, non-medical use and the THC content." Please
tell us your plans
         regarding the potential sale of such products in the 18 states that
restrict its sale and use.
Notes to Consolidated Financial Statements
Note 4 - Debt
PPP Loans, page F-12

3.       Please address the following discrepancies between the disclosures in
this footnote and the
         amounts disclosed in the Consolidated Statements of Operations and the
Consolidated
         Statements of Cash Flows:

                You state the balance of the PPP loans at May 31, 2023 is
$41,666 is recorded in
              Current Liabilities, but the balance sheet shows a balance of $0
at May 31, 2023.
                You state you received forgiveness for the PPP loans in April
2021. Please explain
              what the 2022 and 2023 amounts represent in the line item
"Forgiveness of PPP loan"
              on the Statements of Cash Flows.

        Please contact Ta Tanisha Meadows at 202-551-3322 or Theresa Brillant
at 202-551-
3307 if you have questions regarding comments on the financial statements and
related
matters. Please contact Nicholas Nalbantian at 202-551-7470 or Lilyanna Peyser
at 202-551-
3222 with any other questions.



                                                                Sincerely,

                                                                Division of
Corporation Finance
                                                                Office of Trade
& Services
cc:      Barry J. Miller