Earth science tech, inc.
8000 NW 31ST STREET, UNIT 19
DORAL, FL 33122
July 10, 2019
Jonathan Burr
U.S. Securities & Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Earth Science Tech, Inc. Amendment No. 1 to | |
Registration Statement on Form S-1 Filed May 10, 2019 | ||
| File No. 333-230543 |
Dear Mr. Burr:
By letter dated May 17, 2019, the staff (the “Staff,” “you” or “your”) of the U.S. Securities & Exchange Commission (the “Commission”) provided Earth Science Tech, Inc. (the “Company,” “we,” “us” or “our”) with its comments to the Company’s Amendment No. 1 to Registration Statement on Form S-1 filed on May 10, 2019. We are in receipt of your letter and set forth below are the Company’s responses to the Staff’s comments. For your convenience, the comments are listed below, followed by the Company’s responses.
Amendment No. 1 to Registration Statement on Form S-1 filed May 10, 2019
Special Information Regarding Forward-Looking Statements, page 11
| 1. | We note your revised disclosure in response to comment 4. Please remove references to Section 27A of the Securities Act and Section 21E of the Exchange Act. |
| RESPONSE: | In response to the Staff’s comment, we have removed the references to Section 27A of the Securities Act and Section 21E of the Exchange Act. |
Recent Sales of Unregistered Securities, page II-2
| 2. | We note your revised disclosure in response to comment 16. Please briefly state the facts relied upon to make the exemption available for each of the noted offerings. See Item 701(d) of Regulation S-K. |
| RESPONSE: | In response to the Staff’s comment, we have briefly stated the facts relied upon to make the exemptions available for each of the noted offerings under Recent Sales of Unregistered Securities in page II-2. |
Thank you for your assistance in reviewing this filing.
Very Truly Yours,
Nickolas Tabraue
President
Earth Science Tech, Inc.
8000 NW 31st Street, Unit 19
Doral, FL 33122
