United States securities and exchange commission logo July 20, 2022 Christine Sheehy Chief Financial Officer Coeptis Therapeutics Inc. 105 Bradford Rd, Suite 420 Wexford, Pennsylvania 15090 Re: Coeptis Therapeutics Inc. Form 10-K for the Year Ended December 31, 2021 File No. 000-56194 Dear Ms. Sheehy: We have reviewed your July 7, 2022 response to our comment letter 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 these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our June 23, 2022 letter. Form 10-K for the Year Ended December 31, 2021 Note 3. License Right, page F-10 1. Please expand your disclosures regarding the Co-Development Options to address the significant judgments made and your basis for these judgments in determining that these options have alternative future use and should be recorded as assets pursuant to ASC 730- 10-25-2. Christine Sheehy Coeptis Therapeutics Inc. July 20, 2022 Page 2 You may contact Nudrat Salik at (202) 551-3692 or Tracey Houser at (202) 551-3726 if you have any questions. FirstName LastNameChristine Sheehy Sincerely, Comapany NameCoeptis Therapeutics Inc. Division of Corporation Finance July 20, 2022 Page 2 Office of Life Sciences FirstName LastName