The time-reversed ultrasonically encoded (TRUE) optical focusing technique is a method that is capable of focusing light deep within a scattering medium. This theoretical study aims to explore the depth limits of the TRUE technique for biological tissues in the context of two primary constraints - the safety limit of the incident light fluence and a limited TRUE's recording time (assumed to be 1 ms), as dynamic scatterer movements in a living sample can break the time-reversal scattering symmetry. Our numerical simulation indicates that TRUE has the potential to render an optical focus with a peak-to-background ratio of similar to 2 at a depth of similar to 103 mm at wavelength of 800 nm in a phantom with tissue scattering characteristics. This study sheds light on the allocation of photon budget in each step of the TRUE technique, the impact of low signal on the phase measurement error, and the eventual impact of the phase measurement error on the strength of the TRUE optical focus. (C) 2014 Optical Society of America