July 29, 2019

Nickolas Tabraue
President
Earth Science Tech, Inc.
8000 NW 31st Street, Unit 19
Doral, FL 33122

       Re: Earth Science Tech, Inc.
           Amendment No. 3 to
           Registration Statement on Form S-1
           Filed July 25, 2019
           File No. 333-230543

Dear Mr. Tabraue:

      We have reviewed your amended registration 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 registration 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 registration 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 July 24,
2019 letter.

Form S-1/A3 filed July 25, 2019

General

1.     We note the January 10, 2019 Nevada District Court order states that
"the Court finding
       that Earth Science Tech, Inc. recently becoming an insolvent corporation
is in danger of
       waste ...." It appears that the District Court found that you are
insolvent. However, on
       page 2 you disclose that "the Company sought the appointment of the
receiver after it
       found itself in an imminent danger of insolvency ...." Please reconcile.
2.     We note the January 10, 2019 Nevada District Court order states that the
receiver is to
       take charge of the estate and "to do all other acts which might be done
by the corporation,
       if in being, that may be necessary for the final settlement of the
unfinished business of the
 Nickolas Tabraue
Earth Science Tech, Inc.
July 29, 2019
Page 2
         corporation." It appears that based on the court order the receiver is
winding down the
         corporation. We also note the statement on page 2 that "the intent of
the receiver is to
         reorganize the company ... and emerge from receivership."
Additionally, we note the
         statement that "Stevens and Strongbow assist companies by helping them
raise the capital
         needed not only to pay debts, but build and grow their businesses."
Please reconcile as
         appropriate.
       You may contact Jonathan Burr at 202-551-5833 or David Link at
202-551-3356 with
any questions.



                                                             Sincerely,
FirstName LastNameNickolas Tabraue
                                                             Division of
Corporation Finance
Comapany NameEarth Science Tech, Inc.
                                                             Office of
Beverages, Apparel and
July 29, 2019 Page 2                                         Mining
FirstName LastName