United States securities and exchange commission logo December 1, 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. Registration Statement on Form S-1 Filed November 23, 2020 File No. 333-250887 Dear Mr. Quintero: 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 Jason L. Drory at 202-551-8342 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Alan T. Hawkins