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                              December 28, 2021

       Matthew Wolfson
       Chief Executive Officer and Chief Financial Officer
       Electromedical Technologies, Inc.
       16561 N. 92nd Street, Suite 101
       Scottsdale, AZ 85260

                                                        Re: Electromedical
Technologies, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed December 21,
2021
                                                            File No. 333-261802

       Dear Mr. Wolfson:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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 this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.

       Registration Statement on Form S-1

       Cover Page

   1.                                                   As you are not eligible
to incorporate your future filings by reference because you are a
                                                        penny stock, please
remove the statement that your subsequently filed periodic and current
                                                        reports are
incorporated by reference into the prospectus. See General Instruction
                                                        VII.D to Form S-1.
   2.                                                   Please confirm that you
have executed a binding purchase agreement with White Lion
                                                        LLC and revise the
filing accordingly. While you disclose on this page and throughout
                                                        the filing that the
Purchase Notices with White Lion LLC will be "irrevocable," it is not
                                                        clear if the underlying
agreement is executed and binding.
 Matthew Wolfson
Electromedical Technologies, Inc.
December 28, 2021
Page 2
Exhibit Index, page 120

3.    The majority of the hyperlinked exhibits starting at exhibit 10.5 do not
appear to correctly
      track the exhibits listed in the exhibit index. Please revise. Most
critically, please ensure
      that you have properly filed the Common Stock Purchase and Registration
Rights
      Agreements with White Lion Capital LLC as exhibits. These Agreements are
currently
      listed as having been filed as exhibits 10.21 and 10.22, but the
hyperlinks do not
      correspond to these exhibits nor does it appear that that you filed the
Agreements
      elsewhere.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Dillon Hagius at 202-551-7967 or Laura Crotty at
202-551-7614 with any
questions.



                                                             Sincerely,
FirstName LastNameMatthew Wolfson
                                                             Division of
Corporation Finance
Comapany NameElectromedical Technologies, Inc.
                                                             Office of Life
Sciences
December 28, 2021 Page 2
cc:       Tad Mailander
FirstName LastName