July 1, 2019

Paul R. Arena
Chief Executive Officer
Parallax Health Sciences, Inc.
1327 Ocean Avenue, Suite B
Santa Monica, CA 90401

       Re: Parallax Health Sciences, Inc.
           Form 10-K for the Fiscal Year ended December 31, 2018
           Filed April 1, 2019
           File No. 000-52534

Dear Mr. Arena:

      We have reviewed your filing and have the following comments. In 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.

Form 10-K for the Fiscal Year ended December 31, 2018

General

1.     Please revise your Form 10-K to comply with the comments issued on the
Registration
       Statement on Form S-1 in the letter dated July 1, 2019, as applicable.
Controls and Procedures, page 45

2.     We note your chief executive officer and chief financial officer
concluded that your
       disclosure controls and procedures and your internal control over
financial reporting were
       effective as of the end of the period covered by your annual report.
Please tell us how you
       considered the errors in accounting disclosed at note 14 in reaching
this conclusion. To
       the extent you have identified material weaknesses, please provide the
relevant disclosures
       under Item 308(a)(3) of Regulation S-K. Please also disclose the version
of the
       COSO framework you used to evaluate the effectiveness of your internal
control over
       financial reporting in 2018.
 Paul R. Arena
Parallax Health Sciences, Inc.
July 1, 2019
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.

       You may contact Joanna Lam at 202-551-3476 or Craig Arakawa at
202-551-3650 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Michael Killoy at 202-551-7576 or Pam Howell at 202-551-3357 with any
other
questions.



                                                          Sincerely,
FirstName LastNamePaul R. Arena
                                                          Division of
Corporation Finance
Comapany NameParallax Health Sciences, Inc.
                                                          Office of Beverages,
Apparel and
July 1, 2019 Page 2                                       Mining
FirstName LastName