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                            July 19, 2022

       Adam Hershey
       Chief Executive Officer
       TREES Corporation
       1901 S. Navajo Street
       Denver, Colorado 80223

                                                        Re: General Cannabis
Corp
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2021
                                                            Filed March 25,
2022
                                                            File No. 0-54457

       Dear Mr. Hershey:

               We have reviewed your July 5, 2022 response to our comment
letter and have the
       following comment. In our comment, we may ask you to provide us with
information so we may
       better understand your disclosure.

              Please respond to this comment 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 our
       comment applies to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to this comment, we may have
additional comments.
       Unless we note otherwise, our references to prior comments are to
comments in our June 22,
       2022 letter.

       Form 10-K for the Fiscal Year Ended December 31, 2021

       Item 9A. Controls and Procedures, page 74

   1.                                                   We read your response
to comment 4 and note your proposed disclosure relates to the
                                                        conclusion on
disclosure controls and procedures, as opposed to internal control over
                                                        financial reporting.
Please refer Item 308(a) of Regulation S-K and provide in an
                                                        amended 10-K a report
of management on the company's internal control over financial
                                                        reporting that
contains:

                                                        (1) A statement of
management's responsibility for establishing and maintaining adequate
                                                        internal control over
financial reporting for the registrant;

                                                        (2) A statement
identifying the framework used by management to evaluate the
                                                        effectiveness of the
company's internal control over financial reporting; and
 Adam Hershey
TREES Corporation
July 19, 2022
Page 2

         (3) Management's assessment of the effectiveness of the company's
internal control over
         financial reporting as of the end of the most recent fiscal year,
including a statement as to
         whether or not internal control over financial reporting is effective.
This discussion must
         include disclosure of any material weakness in internal control over
financial reporting
         identified by management. Management is not permitted to conclude that
the company's
         internal control over financial reporting is effective if there are
one or more material
         weaknesses in the company's internal control over financial reporting.
        You may contact Ta Tanisha Meadows at (202) 551-3322 or Adam Phippen at
(202) 551-
3336 if you have any questions.



FirstName LastNameAdam Hershey                                  Sincerely,
Comapany NameTREES Corporation
                                                                Division of
Corporation Finance
July 19, 2022 Page 2                                            Office of Trade
& Services
FirstName LastName