August 14, 2019

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

       Re: Earth Science Tech, Inc.
           Amendment No. 4 to
           Registration Statement on Form S-1
           Filed August 12, 2019
           File No. 333-230543

Dear Mr. Tabraue:

       We have reviewed your amended registration statement and have the
following
comment. In our comment, 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 comment applies 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 this comment, we may have additional comments. Unless we
note
otherwise, our references to prior comments are to comments in our August 9,
2019 letter.

Amendment No. 4 to Registration Statement on Form S-1 filed August 12, 2019

General

1.     We note that the Receiver was tasked by the court to take charge of the
estate and do all
       acts "that may be necessary for the final settlement of the unfinished
business of the
       corporation." This suggests that winding down the affairs of the company
is the primary
       goal of the Receiver. However, the order and S-1 also contemplate stock
issuances, a
       reorganization, emerging from receivership and other possible outcomes.
Do you seek to
       undertake a reorganization or other arrangement to continue the
existence and operations
       of the registrant, instead of winding down the affairs of the company?
If yes, please
       explain in your disclosure why such activities comply with the court
order to finalize
 Nickolas Tabraue
Earth Science Tech, Inc.
August 14, 2019
Page 2
         settlement of the unfinished business of the corporation. In addition,
revise the cover page
         to so state and identify in the summary the principal factors you will
consider in
         determining whether to undertake a reorganization, emergence from
receivership or other
         action in lieu of settlement of the unfinished business of the
company. Also disclose what
         procedures you will follow. For example, would a reorganization or
other arrangement
         require seeking court approval? How and when would disclosure of a
reorganization be
         provided to shareholders and investors? If you do not seek to
undertake such actions
         under the current court order please clarify why you are seeking to
complete an equity line
         financing in connection with the winding down of the company's affairs
and final
         settlement of unfinished business.
       You may contact Jonathan Burr at 202-551-5833 or James Lopez at
202-551-3536 with
any questions.



                                                               Sincerely,
FirstName LastNameNickolas Tabraue
                                                               Division of
Corporation Finance
Comapany NameEarth Science Tech, Inc.
                                                               Office of
Beverages, Apparel and
August 14, 2019 Page 2                                         Mining
FirstName LastName