Global Wholehealth Partners Corp
2227 Avenida Oliva
San Clemente, California 92673
Phone: (714) 392-4112
Email: cstrongo@gmail.com
VIA EDGAR
April 2, 2020
THE UNITED STATES SECURITIES
AND EXCHANGE COMMISSION
Washington, D.C. 20549
Attn: Division of Corporation Finance Office of Life Sciences
Re: | Global Wholehealth Partners Corp Amendment No. 2 to Registration Statement on Form 10-12G Filed March 20, 2020 File No. 000-56035
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Dear Division of Corporation Finance Office of Life Sciences:
On behalf of Global Wholehealth Partners Corp (the “Company”) in response to comment by the United States Securities and Exchange Commission (the “Commission”) in its letter dated April 1, 2020, commenting on the Company’s Registration Statement on Form 10 filed on March 20, 2020 (the “Registration Statement”).
Titling and paragraph numbering of the comments as inserted herein below corresponds to the titling and numbering used in the Commission’s comment letter.
Amendment No. 2 to Registration Statement on Form 10-12G
Item 13. Financial Statements and Supplementary Data, page 31
1. We partially reissue comment eight. Please revise your disclosures under management's discussion and analysis at page 19 to include a comparative analysis and discussion of your financial condition and results of operations for the most recent interim periods presented in your Form 10 to comply with Item 303(b) of Regulation S-X.
Response:We have updated Form 10 Amendment No. 3 to incorporate.
Please feel free to contact me should you require additional information at (714) 392-4112 or cstrongo@gmail.com.
Global Wholehealth Partners Corp
By:/s/ Charles Strongo
Charles Strongo, Chief Executive Officer
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