May 31, 2017

Donald Steinberg
Chief Executive Officer
Marijuana Company of America, Inc.
5256 S. Mission Road, 703 #314
Bonsall, CA 92003

       Re: Marijuana Company of America, Inc.
           Registration Statement on Form 10-12G
           Filed May 23, 2017
           File No. 000-27039
Dear Mr. Steinberg:

         Our preliminary review of your registration statement indicates that
it fails in numerous
material respects to comply with the requirements of the Securities Exchange
Act of 1934, the
rules and regulations under that Act, and the requirements of the form.
Specifically, you have
not provided interim financial statements for the most recent quarterly period
per Rule 8-08 of
Regulation S-X. We will not perform a detailed examination of the registration
statement and we
will not issue comments.

         This registration statement will become effective on July 22, 2017. If
the registration
statement were to become effective in its present form, we would be required to
consider what
recommendation, if any, we should make to the Commission. We suggest that you
consider filing
a substantive amendment correcting the deficiencies or a request for withdrawal
of the
registration statement before it becomes effective.

        Please contact Chris Edwards at (202) 551-6761 or Mary Beth Breslin at
(202) 551-3625
with any questions.



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