June 24, 2019

Robert Davidson
Chief Executive Officer
Cure Pharmaceutical Holding Corp.
1620 Beacon Place
Oxnard, CA 93033

       Re: Cure Pharmaceutical Holding Corp.
           Preliminary Proxy Statement on Schedule 14A
           Filed June 14, 2019
           File No. 000-55908

Dear Mr. Davidson:

       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 providing
the requested
information or advise 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 to these comments, we may have additional
comments.

Preliminary Proxy Statement on Schedule 14A filed June 14, 2019

General

1.    Please include a form of proxy card marked as "preliminary" in your next
amendment.
2.    We note that your forum selection provision identifies a state court
located within the
      State of Delaware (or, if the Court of Chancery does not have
jurisdiction, the federal
      district court for the District of Delaware) as the exclusive forum for
certain litigation,
      including any "derivative action." Please disclose whether this provision
applies to actions
      arising under the Securities Act or Exchange Act. If so, please also
state that there is
      uncertainty as to whether a court would enforce such provision. In that
regard, we note
      that Section 22 of the Securities Act creates concurrent jurisdiction for
federal and state
      courts over all suits brought to enforce any duty or liability created by
the Securities Act
      or the rules and regulations thereunder. If this provision does not apply
to actions arising
      under the Securities Act or Exchange Act, please also ensure that the
exclusive forum
      provision in the governing documents states this clearly, or tell us how
you will inform
 Robert Davidson
Cure Pharmaceutical Holding Corp.
June 24, 2019
Page 2
      investors in future filings that the provision does not apply to any
actions arising under the
      Exchange Act.
        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.

       Please contact Sergio Chinos, Staff Attorney, at (202) 551-7844 or Asia
Timmons-Pierce,
Special Counsel, at (202) 551-3754 with any questions.



                                                             Sincerely,

FirstName LastNameRobert Davidson                            Division of
Corporation Finance
                                                             Office of
Manufacturing and
Comapany NameCure Pharmaceutical Holding Corp.
                                                             Construction
June 24, 2019 Page 2
cc:       Peter DiChiara
FirstName LastName