CORRESP 1 filename1.htm SEC Response Letter


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Securities and Exchange Commission

Division of Corporate Finance

Washington, D. C.  20549


March 2, 2017


Attn:  Kevin J. Kuhar

Accounting Branch Chief

Office of Electronics and Machinery



Re:  Therapeutic Solutions International, Inc.

Form 10-K for the Fiscal Year Ended December 31, 2015 Filed October 31, 2016 and Form 10-K/A filed on January 25, 2017


File No.  000-54554


Dear Mr. Kuhar:


Please see our updated response to Item 4 below to your letter of December 21, 2016:


Form 10-K for the Fiscal Year Ended December 31, 2015


Management's Annual Report on Internal Control over Financial Reporting, page 25


4.  We note that your Management´s Report on Internal Control over Financial Reporting does not identify the version of the Committee of Sponsoring Organizations of the Treadway Commission (COSO) Internal Control - Integrated Framework that was used to perform your assessment as required by Item 308(a)(2) of Regulation S-K. Please tell us the COSO framework used by your management - i.e., whether you used the 1992 Framework or the Updated Framework issued in 2013, and revise the report in future filings to identify the framework used.


Updated response:


An inadvertent typographical error occurred in the filing of our Form 10-K/A on January 25, 2017 that resulted in an incorrect Committee of Sponsoring Organizations of the Treadway Commission (COSO) Internal Control - Integrated Framework date used to evaluate Internal Control.  The correct date should have been 2013.


Our Management´s Report on Internal Control over Financial Reporting will use the Committee of Sponsoring Organizations of the Treadway Commission (COSO) Internal Control Updated Framework issued in 2013 for our Form 10-Q and Form 10-K filings for 2016 and 2017.


Sincerely,



/s/ Gerry B. Berg

Gerry B. Berg

Chief Financial Officer

Therapeutic Solutions International, Inc.


cc:  Tara Harkins



4093 Oceanside Blvd., Suite B. Oceanside, CA  92056