September 14, 2018

Todd Higley
Chief Executive Officer
Vortex Brands, Inc.
3511 Del Paso Rd., Ste. 160 PMB 208
Sacramento, CA 95835

       Re: Vortex Brands, Inc.
           Amendment No. 1 to
           Offering Statement on Form 1-A
           Filed September 4, 2018
           File No. 024-10875

Dear Mr. Higley:

      We have reviewed your amended offering statement 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 this letter by amending your offering statement and
providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your offering statement and the
information you
provide in response to these comments, we may have additional comments. Unless
we note
otherwise, our references to prior comments are to comments in our August 23,
2018 letter.

Form 1-A Amended September 4, 2018

Business of Registrant, page 17

1.    We note your disclosure added in response to prior comment 3. Please
revise
      to clarify the current stage of development of the blockchain technology
you intend to
      implement.
2.    Please expand your revisions in response to prior comment 4 to clarify
your current and
      intended operations. For example, explain what you mean by acting as
"central contract
      administrator in coordinating the efforts of all parties" and how this
will result in revenues
 Todd Higley
Vortex Brands, Inc.
September 14, 2018
Page 2
         for you. Also revise to explain the current status of operations of
the other parties with
         whom you will work, such as Tripac's manufacturing capabilities and
Fazync's ability to
         maintain and install the proposed product. Also tell us the source of
the irrevocable right
         and custodial right to which you refer and file those documents as
exhibits. Finally, we
         note the disclosure regarding finalizing the pilot program and
refining the manufacturing
         and installation process. Expand to clarify what steps remain to
accomplish these
         objectives, including any material hurdles.
3.       Please expand your revisions in response to prior comment 5 to
highlight the affiliation
         among you and the entities referenced in your disclosure, including
shared officers and
         directors. Please also revise to explain the purpose of assigning each
affiliated entity a
         different operational role, as noted on page 18. Also, tell us how you
determined there
         were no transactions requiring disclosure under Item 13 to Form 1-A.
Preferred Series C Stock, page 29

4.       Please address that portion of prior comment 6 that asked you to
revise to clarify whether
         the anti-dilution features disclosed on page 30 will be triggered as a
result of this
         offering. If so, please tell us whether you will have sufficient
authorized share capital to
         fully conduct the offering after potential conversions.
Exhibits

5.       Please address that portion of prior comment 8 that asked you to
clarify how you
         determined that paragraphs 3.d, 4.g, 4.j and 4.k of exhibit 4.1 are
appropriate and
         consistent with the federal securities laws.
        You may contact Gary Newberry at 202-551-3761 or Kevin Kuhar,
Accounting Branch
Chief, at 202-551-3662 if you have questions regarding comments on the
financial statements
and related matters. Please contact Caleb French at 202-551-6947 or Geoff
Kruczek, Senior
Attorney at 202-551-3641 with any other questions.



FirstName LastNameTodd Higley                                  Sincerely,
Comapany NameVortex Brands, Inc.
                                                               Division of
Corporation Finance
September 14, 2018 Page 2                                      Office of
Electronics and Machinery
FirstName LastName