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                             April 12, 2022

       William Scott Tudor
       Chief Executive Officer
       Water Technologies International, Inc.
       1432-B Skees Road
       West Palm Beach, FL 33411

                                                        Re: Water Technologies
International, Inc.
                                                            Amendment No. 1 to
Offering Statement on Form 1-A
                                                            Filed March 30,
2022
                                                            File No. 024-11817

       Dear Mr. Tudor:

             We have reviewed your amended offering statement and have the
following
       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 offering 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 offering statement and the
information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our March
15, 2022 letter.

       Amendment No. 1 to Offering Statement on Form 1-A

       Our Business, page 18

   1.                                                   We note your response
to prior comment 1. You state on page 18 that under your Mutual
                                                        Teaming Agreement with
Terra Sustainable Technologies, Inc., you plan to work together
                                                        to offer AWGs powered
by alternative energy. However, it appears that the Mutual
                                                        Teaming Agreement
terminated 6 months after the date the agreement was signed on June
                                                        6, 2021, according to
section 5 of the agreement. Please advise or revise your disclosure.
       Exhibits

   2.                                                   We note your response
to prior comment 2. It appears you have four convertible
                                                        promissory notes with
outstanding balances, but have filed as exhibits only two of those
 William Scott Tudor
Water Technologies International, Inc.
April 12, 2022
Page 2
      notes. Further, you disclose on page 24 that you entered into account
future receipts
      financings with Liberty Funding Solutions and Pac Western Financial, LLC,
but only filed
      the agreement made with Pac Western, LLC. The agreement with Celtic Bank
      Corporation, filed as Exhibit 6.5, appears to be a personal guaranty made
by your CEO in
      favor of the bank. Please disclose this guaranty in your offering
circular and file a copy of
      the related financing agreement with Celtic Bank. If Exhibit 6.1 relates
to the agreement
      you describe on page 23 as the LOC Note I, revise your disclosure to
state that this
      agreement was amended on June 4, 2021 (the "Fourth Addendum"). Please
file
      these agreements and make the related disclosures or advise.
      Please contact Patrick Faller, Staff Attorney, at (202) 551-4438 or Jan
Woo, Legal
Branch Chief, at (202) 551-3453 with any questions.



                                                            Sincerely,
FirstName LastNameWilliam Scott Tudor
                                                            Division of
Corporation Finance
Comapany NameWater Technologies International, Inc.
                                                            Office of
Technology
April 12, 2022 Page 2
cc:       Eric Newlan
FirstName LastName