November 4, 2019

Paul R. Arena
Chief Executive Officer
Parallax Health Sciences, Inc.
1327 Ocean Avenue, Suite B
Santa Monica, CA 90401

       Re: Parallax Health Sciences, Inc.
           Amended Form 10-K for the Fiscal Year ended December 31, 2018
           Filed October 21, 2019
           File No. 000-52534

Dear Mr. Arena:

       We have reviewed your amended filing 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 these comments 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
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.
Unless we note other wise, our references to prior comments are to comments in
our August 8,
2019 letter.

Amendment No.2 to the Form 10-K for fiscal year ended December 31, 2018

General

1.     Please revise your Form 10-K to comply with the comments issued on the
Amended
       Registration Statement on Form S-1 in the letter dated November 4, 2019,
as applicable.
Controls and Procedures, page 56

2.     We note your management concluded that your disclosure controls and
procedures and
       internal control over financial reporting were effective as of the end
of the period covered
       by your annual report. Given the fact that you have restated your
previously issued
       financial statements due to errors in the accounting for certain
convertible debt, warrants
       and convertible preferred stock, please address the following points:
 Paul R. Arena
Parallax Health Sciences, Inc.
November 4, 2019
Page 2
              Tell us why you did not disclose that these restatements were
indicative of a material
              weakness in your internal control over financial reporting to
comply with Item
              308(a)(3) of Regulation S-K.
              Tell us how your officers determined that your disclosure
controls and procedures
              were effective despite such material weakness in your internal
controls over financial
              reporting.
              Tell us which COSO framework was used by your management in the
evaluating the
              effectiveness of your internal control over financial reporting.

         Please note that this comment also applies to the Form 10-Q for the
interim period ended
         June 30, 2019.
Exhibits

3.       We reissue comment two. Please refile your exhibits in the proper
text-searchable
         format. Please refer to Section 5.2.3.6 of the EDGAR File Manual
(Volume II) EDGAR
         Filing (Version 49) (December 2018) and Item 301 of Regulation S-T.
       You may contact Joanna Lam at 202-551-3476 or Craig Arakawa at
202-551-3650 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Michael Killoy at 202-551-7576 or Pam Howell at 202-551-3357 with any
other
questions.



FirstName LastNamePaul R. Arena                                Sincerely,
Comapany NameParallax Health Sciences, Inc.
                                                               Division of
Corporation Finance
November 4, 2019 Page 2                                        Office of Real
Estate & Construction
FirstName LastName