June 27, 2019

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

       Re: Cure Pharmaceutical Holding Corp.
           Amendment No. 1 to Preliminary Proxy Statement on Schedule 14A
           Filed June 26, 2019
           File No. 000-55908

Dear Mr. Davidson:

       We have reviewed your filing and have the following comment.

       Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Amendment No. 1 to Preliminary Proxy Statement on Schedule 14A

General

1.    We note your response to comment 2 of our prior letter that your
exclusive forum
      provision does not apply to the Securities Act or Exchange Act. Please
ensure that the
      exclusive forum provision in the governing documents states this clearly,
or tell us how
      you will inform investors in future filings that the provision does not
apply to any actions
      arising under the Exchange Act. We note that Article XI of your Bylaws
states that the
      federal district courts of the United States of America shall be the
exclusive forum for the
      resolution of any complaint asserting a cause of action arising under the
Securities Act of
      1933, which is inconsistent with your disclosure. Please address this
inconsistency with
      your disclosures and Article XI.


        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.
 Robert Davidson
Cure Pharmaceutical Holding Corp.
June 27, 2019
Page 2

       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 27, 2019 Page 2
cc:       Peter DiChiara
FirstName LastName