April 3, 2018

William Waldrop
CEO
EVIO, INC.
62930 O. B. Riley Rd
Suite 300
Bend, OR 97703

       Re: EVIO, INC.
           Form 10-K for the Year-end September 30, 2017
           Filed January 17, 2018
           File No. 000-12350

Dear Mr. Waldrop:

       We have reviewed your filing 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 amending
your filing or by
advising 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 and any amendment you may file in response
to these
comments, we may have additional comments.

Form 10-K for the Year-end September 30, 2017

Item 1. Business, page 4

1.    Please expand to discuss the nature of your advisory and research
services in the cannabis
      industry. Describe in greater detail your compliance testing services. We
refer you to
      Item 101(c) of Regulation S-K, and we note, as examples only, the
requirements for
      discussion of the nature of your customers, your competition, your
marketing practices,
      and the impact of federal and state and local regulation on your
business.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page 8

2.    The cultivation, distribution and possession of marijuana remains illegal
under federal
 William Waldrop
FirstName LastNameWilliam Waldrop
EVIO, INC.
Comapany NameEVIO, INC.
April 3, 2018
June 16, 2017 Page 2
Page 2
FirstName LastName
         law. We note that you operate your laboratories where medical
marijuana is legal under
         state law. Discuss the impact that regulatory uncertainty has had, and
is likely to have in
         the future, on your financial condition and results of operations.
3.       We note your statement under "Item 1A. Risk Factors" highlighting that
even though a
         discussion of material risks facing the company is not required under
the rules, there are
         risks of which shareholders and prospective investors should be aware.
Please expand
         your MD&A to address how these risks have affected, and are expected
to affect, your
         results of operation and financial condition and the steps management
has taken, and is
         planning on taking, to insure adequate risk assessment and execution
to reduce loss
         exposure.
Executive Compensation, page 18

4.       Please revise to quantify the compensation received by Newport
Commercial Advisors
         referred to in footnote 1.
Certain Relationships and Related Transactions, page 19

5.       We note the absence of disclosure under this Item. Include a cross
reference to your
         disclosure in Note 7 to your financial statements.
Item 15. Exhibits, page 20

6.       Please revise to include all required exhibits, including, for
example, the company's
         articles of incorporation and bylaws and all material contracts. We
refer you to Item 601
         of Regulation S-K.
Financial Statements
Note 3 - Acquisitions
Viridis Analytics MA, LLC, page F-15

7.       We note that your Form 8-K dated July 26, 2017 does not include
historical financial
         statements and pro forma information related to your purchase of
Viridis Analytics MA,
         LLC. It appears that this transaction may have exceeded the reporting
thresholds of Rule
         8-04 of Regulation S-X. Give us your calculations and explain for us
your consideration
         of whether or not audited financial statements and pro forma
information for this
         acquisition is required to be filed under cover of Form 8-K.



        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.
 William Waldrop
EVIO, INC.
April 3, 2018
Page 3

       You may contact Joseph M. Kempf, Senior Staff Accountant, at
202-551-3352 or Carlos
Pacho, Senior Assistant Chief Accountant, at 202-551-3835 if you have questions
regarding
comments on the financial statements and related matters. Please contact
Gregory Dundas, Staff
Attorney, at 202-551-3436 or Larry Spirgel, Assistant Director, at 202-551-3810
with any other
questions.


FirstName LastNameWilliam Waldrop
                                                          Division of
Corporation Finance
Comapany NameEVIO, INC.
                                                          Office of
Telecommunications
June 16, 2017 Page 3
cc: Christian Carnell
FirstName LastName