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                            December 11, 2020

       Dominic Colvin
       Chief Executive Officer
       CannaPharmaRx, Inc.
       888     3rd Street SW, Suite 3600
       Calgary, Alberta, CanadaT2P 5C5

                                                        Re: CannaPharmaRx, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed November 27,
2020
                                                            File No. 333-251016

       Dear Mr. Colvin:

              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 November 27, 2020

       Cover Page

   1.                                                   We note that your
common stock is quoted on the OTC Pink marketplace. Our
                                                        accommodation
permitting the resale of shares to be issued under an equity line agreement
                                                        is available only where
there is an existing market for the securities. Please remove the
                                                        resale offering by
Granite Global Value Investments, LTD. of up to 22,017,682 shares of
                                                        common stock issuable
under the securities purchase agreement. Alternatively, you may
                                                        register the resale of
the equity line securities after each put.
   2.                                                   Please note that the
OTC Pink marketplace is not an established public trading market into
                                                        which selling
stockholders may offer and sell their shares of common stock at other than a
                                                        fixed price.
Accordingly, please revise your cover page disclosure, and make
                                                        corresponding changes
elsewhere in the prospectus, to disclose a fixed price at which the
 Dominic Colvin
CannaPharmaRx, Inc.
December 11, 2020
Page 2
       selling shareholders other than Granite will sell their shares of your
common stock until
       your shares are listed on a national securities exchange or quoted on
the OTC Bulletin
       Board, OTCQX or OTCQB, at which time they may be sold at prevailing
market prices or
       in privately negotiated transactions. Refer to Item 501(b)(3) of
Regulation S-K.
Incorporation of Certain Information by Reference, page 56

3.     We note that you have elected to incorporate information by reference
pursuant to General
       Instruction VII. If you elect to incorporate information by reference,
you must
       specifically incorporate by reference the documents referenced in Item
12(a) of Form S-1
       into the prospectus. Please revise accordingly.
Signatures, page II-6

4.     Please include a signature for your principal financial officer and your
controller or
       principal accounting officer. If someone has signed in more than one
capacity, please
       indicate each capacity in which they have signed. Refer to Instructions
to Signatures on
       Form S-1.
        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 Jeffrey Gabor at 202-551-2544 or Mary Beth Breslin at
202-551-3625
with any questions.



                                                             Sincerely,
FirstName LastNameDominic Colvin
                                                             Division of
Corporation Finance
Comapany NameCannaPharmaRx, Inc.
                                                             Office of Life
Sciences
December 11, 2020 Page 2
cc:       Joshua D. Brinen, Esq.
FirstName LastName