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                              October 26, 2023

       Todd R. Hackett
       Chief Executive Officer
       PCS Edventures!, Inc.
       11915 W. Executive Drive, Suite 101
       Boise, Idaho 83713

                                                        Re: PCS Edventures!,
Inc.
                                                            Form 10-12G
                                                            Filed October 3,
2023
                                                            File No. 000-49990

       Dear Todd R. Hackett:

                                                        We have reviewed your
filing and have the following comments.

              Please respond to this letter within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Form 10-12G filed on October 3, 2023

       Item 2. Financial Information
       Management's Discussion and Analysis
       Results of Operations for the Years Ended March 31, 2023 and 2022 and
the Quarters Ended
       June 30, 2023 and 2022
       Revenues, page 10

   1.                                                   Please expand your
discussion of period to period changes in each income statement line
                                                        item to include
specific facts and circumstances contributing to each variance. For
                                                        example, we note from
your disclosure on page F-10 that the October 2022 contract with
                                                        the United States Air
Force Junior Reserve Officers    Training Corps and the January 2023
                                                        contract with the Iowa
Governor   s STEM Advisory Council appear to have contributed to
                                                        a substantial portion
of the increases, and if true should be included in your discussion of
                                                        substantial increases
in revenue. Further, please consider expanding your disclosure to
                                                        also include a
discussion of variances in the five main categories of STEM education
                                                        products and services
that you sell as detailed on page F-6. Please include in your
                                                        disclosure tabular
presentation of revenue recognized in each of these categories for each
 Todd R. Hackett
FirstName LastNameTodd    R. Hackett
PCS Edventures!, Inc.
Comapany
October 26,NamePCS
            2023      Edventures!, Inc.
October
Page 2 26, 2023 Page 2
FirstName LastName
         period an income statement is presented. Your discussions of cost of
sales and other
         income statement line items should be similarly revised. Refer to the
guidance in Item
         303(b)(2) of Regulation S-K.
Management's Discussion and Analysis, page 10

2.       In its current form, your discussion appears relatively brief.
Accordingly, please expand
         your disclosure, as applicable, to fully address Item 303 of
Regulation S-K. In this regard,
         your discussion should address your past and future financial
condition and results of
         operation, with particular emphasis on the prospects for the future.
Your discussion should
         also address those key variable and other qualitative and quantitative
factors which are
         necessary for an understanding of your operations. We note your
disclosure concerning
         Covid-19. Please describe and quantify, to the extent possible, any
known trends and
         uncertainties that have had or that you reasonably expect will have a
material favorable or
         unfavorable impact on your revenue or results of operations, in light
of the impact of
         COVID-19 on your business. In addition and if applicable, please
clarify whether inflation
         has had or is expected to have a material impact on your operations
and financial
         results. Please also discuss whether supply chain disruptions have
materially affected your
         operations, outlook or business goals.
Transactions with Related Persons, page 15

3.       We note that in the third paragraph you disclose, "the Company
executed a non-
         convertible promissory note with no warrants attached with a member of
the Executive
         Management Team and Board of Directors, for $50,000 at 20% interest
per
         annum." Please identify the individual that borrowed the money. See
Item 404(d) of
         Regulation S-K.
Market Price of and Dividends on the Registrant's Common Equity and Related
Stockholder
Matters, page 16

4.       Provide the trading price information required by Item 201(a)(iii) of
Regulation S-K to the
         extent known to management.
Item 15. Financial Statements and Exhibits, page 20

5.       Please confirm that you have filed all material contracts. Refer to
Item 601(b)(10) of
         Regulation S-K. In this regard, we note that you have a lease
agreement and a contract
         with the United States Air Force Junior Reserve Officers' Training
Corp. We also note
         that the United States Air Force JROTC appears to be your largest
customer. Please
         confirm or, alternatively, file all material contracts and revise the
exhibit index as
         applicable.
Audited Financial Statements for the Years Ended March 31, 2023 and 2022
Note 1 - Description of Business and Significant Accounting Policies
Revenue Recognition, page F-8
 Todd R. Hackett
PCS Edventures!, Inc.
October 26, 2023
Page 3

6.       Please disclose disaggregated revenue as required by FASB ASC
606-10-50-5 through 7.
Note 9 - Income Taxes, page F-14

7.       Please disclose the amounts and expiration dates of operating loss
carryforwards for tax
         purposes. Refer to ASC 740-10-50-3a.
Unaudited Financial Statements
Consolidated Statements of Operations for the Three Months Ended June 30, 2023
and 2022,
page F-19

8.       Referencing authoritative literature to support your conclusion,
please explain to us how
         you determined $0 income tax impact for in the interim periods
presented. Refer to ASC
         740-270.
General

9.       We note that you are voluntarily registering your common stock under
Section 12(g) of
         the Securities Exchange Act of 1934. Please note that the Form 10 goes
effective
         automatically by lapse of time 60 days after the original filing date.
If our comments are
         not addressed within this 60-day time period, you should withdraw the
Form 10 prior to
         effectiveness and refile a new Form 10 including changes responsive to
our comments. If
         you choose not to withdraw, you will be subject to the reporting
requirements under
         Section 13(a) of the Securities Exchange Act of 1934. In addition, we
will continue to
         review your filing until all of our comments have been addressed.
        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 Amy Geddes at 202-551-3304 or Adam Phippen at
202-551-3336 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Scott Anderegg at 202-551-3342 or Donald Field at 202-551-3680 with any
other
questions.



FirstName LastNameTodd R. Hackett                             Sincerely,
Comapany NamePCS Edventures!, Inc.
                                                              Division of
Corporation Finance
October 26, 2023 Page 3                                       Office of Trade &
Services
FirstName LastName