August 9, 2019

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

       Re: Earth Science Tech, Inc.
           Registration Statement on Form S-1
           Response dated August 2, 2019
           File No. 333-230543

Dear Mr. Tabraue:

       We have reviewed your supplemental response 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 29,
2019 letter.

Response dated August 2, 2019

General

1.     We note your draft disclosure provided in response to comment 2. In this
regard, we note
       the statement that "The Receiver also intends to optimize the affairs of
the Company by
       identifying business opportunities that he expects will allow the
Company to utilize its
       portfolio of cannabidiol related assets and operations and emerge from
receivership in a
       better position to create and maximize value for its shareholders."
Please delete this
       statement of the Receiver's expectation or disclose the most significant
assumptions upon
       which the expectation depends. For example, it is unclear on what basis
you believe the
       company can emerge from receivership in a better position to create and
maximize value
       for shareholders without obtaining the approximately $4 million owed
under the
 Nickolas Tabraue
Earth Science Tech, Inc.
August 9, 2019
Page 2
         arbitration award for which the company sought receivership.
2.       It appears that the receiver is an executive officer as defined under
Rule 405. Please
         disclose the information required by Item 404 of Regulation S-K. For
example only,
         please disclose the material terms of the receiver's compensation and
the amount of
         compensation he has accrued to date.
       You may contact Jonathan Burr at 202-551-5833 or James Lopez at
202-551-3536 with
any questions.



                                                              Sincerely,
FirstName LastNameNickolas Tabraue
                                                              Division of
Corporation Finance
Comapany NameEarth Science Tech, Inc.
                                                              Office of
Beverages, Apparel and
August 9, 2019 Page 2                                         Mining
FirstName LastName