April 26, 2018

Amro Albanna
Chief Executive Officer
ADiTx Therapeutics, Inc.
11161 Anderson St., Suite 105-10014
Loma Linda, CA 92354

       Re: ADiTx Therapeutics, Inc.
           Offering Statement on Form 1-A
           Filed on March 30, 2018
           File No. 024-10825

Dear Mr. Albanna:

       We have reviewed your offering statement 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 this letter by amending your offering 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 offering statement and the
information you
provide in response to these comments, we may have additional comments.

Offering Statement on Form 1-A

General

1.    Please fill in the blanks in the document with your next amendment.
2.    Please disclose whether the underwriter, any affiliate of the issuer, or
any other party in
      the marketing of the securities reserves the right to purchase securities
in the primary
      offering in order to meet the minimum purchase requirements. If so,
please also disclose
      the amount of securities that may be purchased and include an appropriate
risk factor.
3.    We note your disclosure on page F-11 that you are a party to a consulting
agreement for
      project management services. If this agreement is material to you, please
describe its
      material terms and file it as an exhibit to your registration statement
or advise.
 Amro Albanna
FirstName LastNameAmro Albanna
ADiTx Therapeutics, Inc.
Comapany NameADiTx Therapeutics, Inc.
April 26, 2018
June 16, 2017 Page 2
Page 2
FirstName LastName
4.       Please include information required by Item 510 of Regulation S-K.
Risk Factors
Our technology is subject to a license from LLU, page 12

5.       We note your disclosure that the next Milestone Deadline is the
requirement to complete a
         financing round by July 31, 2018. Please clarity what constitutes a
financing round under
         the agreement and address if there is a risk you may not be able to
meet that milestone
         deadline.
Use of Proceeds, page 26

6.       Please disclose the interest rate and maturity of the existing debt
you plan to repay with
         the proceeds from this offering. Refer to Instruction 4 to Item 504 of
Regulation S-K. In
         addition, please disclose the amount of the licensing fee you plan to
pay to Loma Linda
         University, as described on the cover page of the offering statement.
Our Business, page 31

7.       Please include a detailed plan of operations for the next twelve
months. In the discussion
         of each of your planned activities, include specific information
regarding each material
         event or step required to pursue each of your planned activities,
including any
         contingencies such as raising additional funds, and the timelines and
associated costs
         accompanying each proposed step in your business plan.
8.       Please clarify in this section, if true, that you have not yet
submitted an application for any
         products to the FDA.
9.       Please disclose the number of your employees. Refer to Item
101(h)(4)(xii) of Regulation
         S-K.
License Agreement with Loma Linda University, page 35

10.      Please clarify what is meant by you will owe "low single-digit royalty
payments on any
         Licensed Products." Please explain for example, if the royalty
payments will be per unit
         sold, or otherwise. Please also quantify to the extent practicable or
advise.
Directors, Executive Officers & Corporate Governance
Executive Officers, Directors and Significant Employees, page 39

11.      Please discuss the specific experience, qualifications, attributes or
skills of each director
         that led to the conclusion that the person should serve as a director.
Refer to Item 401(e)
         of Regulation S-K.
Escrow Agent and Deposit of Offering Proceeds, page 49

12.      Please file the Escrow Agreement as an exhibit.
 Amro Albanna
ADiTx Therapeutics, Inc.
April 26, 2018
Page 3

        We will consider qualifying your offering statement at your request. If
a participant in
your offering is required to clear its compensation arrangements with FINRA,
please have
FINRA advise us that it has no objections to the compensation arrangements
prior to
qualification.

        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. We also remind you that, following qualification of your
Form 1-A, Rule 257
of Regulation A requires you to file periodic and current reports, including a
Form 1-K which
will be due within 120 calendar days after the end of the fiscal year covered
by the report.

       You may contact Abe Friedman at )202) 551-8298 or Jean Yu at (202)
551-3305 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Tonya K. Aldave at (202) 551-3601 or Susan Block at (202) 551-3210 with
any other
questions.


FirstName LastNameAmro Albanna
                                                             Division of
Corporation Finance
Comapany NameADiTx Therapeutics, Inc.
                                                             Office of
Transportation and Leisure
June 16, 2017 Page 3
cc: Richard Friedman
FirstName LastName