September 3, 2019 Erin Phillips CEO STWC Holdings, Inc. 1350 Independence Street Suite 300 Lakewood, CO 80215 Re: STWC Holdings, Inc. Registration Statement on Form S-1 Filed August 23, 2019 File No. 333-233429 Dear Ms. Phillips: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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 Jennifer Gowetski at 202-551-3401 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate and Commodities