September 19, 2019

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

       Re: Earth Science Tech, Inc.
           Amendment No. 5 to
           Registration Statement on Form S-1
           Filed September 11, 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 August 14,
2019 letter.

Amendment No. 5 to Registration Statement on Form S-1 Filed September 11, 2019

General

1.     We note your response to comment 1 and that the receiver's intent is to
reorganize the
       company. Please tell us what you mean by reorganization. For example, do
you intend to
       restructure the company's current debt? Or do you intend to complete an
acquisition or
       merger transaction? Will the company continue to operate its current
business plan? Will
       management continue to operate the company after emerging from
receivership? We may
       have further comment.
2.     Please revise to disclose the statements provided in your response
letter regarding the Mr.
       Stevens having "all powers of a receiver granted by statute which are
extremely broad and
 Nickolas Tabraue
Earth Science Tech, Inc.
September 19, 2019
Page 2
         necessarily include reorganizing and winding up the corporation. It is
not necessary for
         the court to state that he has the power to reorganize the corporation
or that he have the
         power to liquidate it. Those powers are granted by statute when he is
appointed as a
         receiver." Please also disclose the timing and steps to be taken in
finalizing a plan of
         reorganization and getting it ratified by the court as discussed in
your response letter.
Consolidated Financial Statements and Notes, page F-1

3.       Please amend your filing to include updated financial statements
pursuant to Rule 8-08 of
         Regulation S-X. In addition, disclosure throughout your filing should
also be updated to
         conform to the additional information that will be provided in your
updated financial
         statements.
       You may contact Steve Lo at 202-551-3394 or Joel Parker at 202-551-3651
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Jonathan Burr at 202-551-5833 or James Lopez at 202-551-3536 with any other
questions.



                                                                Sincerely,
FirstName LastNameNickolas Tabraue
                                                                Division of
Corporation Finance
Comapany NameEarth Science Tech, Inc.
                                                                Office of
Beverages, Apparel and
September 19, 2019 Page 2                                       Mining
FirstName LastName