United States securities and exchange commission logo March 5, 2021 Richard E. Davis Chief Financial Officer Arch Therapeutics, Inc. 235 Walnut Street, Suite 6 Framingham, MA 01702 Re: Arch Therapeutics, Inc. Registration Statement on Form S-1 Filed February 26, 2021 File No. 333-252588 Dear Mr. Davis: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Abby Adams at (202) 551-6902 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Park S. Bramhall, Esq.