October 16, 2018

Paris Balaouras
Chief Executive Officer
MJ Holdings, Inc.
3275 South Jones Blvd.
Las Vegas, Nevada 89146

       Re: MJ Holdings, Inc.
           Registration Statement on Form S-1
           Filed October 5, 2018
           File No. 333-227735

Dear Mr. Balaouras:

     We have limited our review of your registration statement to the issue
addressed in our
comment.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comment applies 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 registration statement and the
information you
provide in response to this comment, we may have additional comments.

Form S-1 filed October 5, 2018

General

1.     The selling shareholders intend to sell their shares at market prices,
and your shares are
       presently quoted on the OTC Pink marketplace. To sell shares at market
prices, we require
       an existing trading market for those shares. We do not consider the OTC
Pink
       Marketplace to be such a market for the purposes of satisfying Item
501(b)(3) of
       Regulation S-K. Please revise the filing, providing a fixed price for
this offering until
       such a time as your shares are listed on a national securities exchange,
until you are
       quoted on the OTC Bulletin Board, or until you are quoted on the OTCQX
or the
       OTCQB.
 Paris Balaouras
MJ Holdings, Inc.
October 16, 2018
Page 2

        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

      Please contact Charlie Guidry, Staff Attorney, at 202-551-3621 or Lisa
Kohl, Legal
Branch Chief, at 202-551-3252 with any questions.



FirstName LastNameParis Balaouras                          Sincerely,
Comapany NameMJ Holdings, Inc.
                                                           Division of
Corporation Finance
October 16, 2018 Page 2                                    Office of Consumer
Products
FirstName LastName