February 4, 2020

Jesus Quintero
Chief Executive Officer
Marijuana Co of America, Inc.
1340 West Valley Parkway
Suite 205
Escondido, CA 92029

       Re: Marijuana Co of America, Inc.
           Form 10-K for Fiscal Year Ended December 31, 2018
           Form 10-K for Fiscal Year Ended December 31, 2017
           File No. 000-27039

Dear Mr. Quintero:

       We have completed our review of your filing. 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.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Life
Sciences
cc:    Tad Mailander, Esq.