United States securities and exchange commission logo April 7, 2021 Timothy Young Chief Executive Officer SunHydrogen, Inc. 10 E. Yanonali St. Suite 36 Santa Barbara, California 93101 Re: SunHydrogen, Inc Form 10-K for the Fiscal Year Ended June 30, 2020 Filed September 23, 2020 File No. 000-54437 Dear Mr. Young: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to the comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the Fiscal Year Ended June 30, 2020 Report of Independent Registered Public Accounting Firm, page F-1 1. Based on the requirements of paragraphs 12 and 13 of PCAOB Auditing Standard 2415, an appropriately titled going concern paragraph included in an auditors' report should immediately follow the opinion paragraph. Please file an amendment to have your current auditor ensure that their audit report fully complies. Timothy Young SunHydrogen, Inc. April 7, 2021 Page 2 In closing, 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. You may contact Andi Carpenter at 202-551-3645 or Sisi Cheng at 202-551-5004 with any questions. FirstName LastNameTimothy Young Sincerely, Comapany NameSunHydrogen, Inc. Division of Corporation Finance April 7, 2021 Page 2 Office of Manufacturing FirstName LastName