TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo October 7, 2021 Timothy Warbington Chief Executive Officer Creative Medical Technology Holdings, Inc. 211 E. Osborn Road Phoenix, AZ 85012 Re: Creative Medical Technology Holdings, Inc. Registration Statement on Form S-1 Filed September 28, 2021 File No. 333-259834 Dear Mr. Warbington: We have limited our review of your registration statement to those issues we have addressed in our comment. In our comment, 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 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 the comment, we may have additional comments. Registration Statement on Form S-1 filed September 28, 2021 Cover page 1. We note your disclosure that the units will be offered at an "assumed" price. We further note that you are subject to the reporting requirements of Section 13(a) or 15(d) of the Exchange Act, as applicable. Please revise to state the price of the securities to the public. If you are not able to state the price, explain the method by which the price is to be determined. Refer to Instruction 2 to Item 501(b)(3) of Regulation S-K. 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. Timothy Warbington Creative Medical Technology Holdings, Inc. October 7, 2021 Page 2 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. Please contact Celeste Murphy at 202-551-3257 or Christine Westbrook at 202-551- 5019 with any questions. Sincerely, FirstName LastNameTimothy Warbington Division of Corporation Finance Comapany NameCreative Medical Technology Holdings, Inc. Office of Life Sciences October 7, 2021 Page 2 cc: Zev M. Bomrind, Esq. FirstName LastName