February 7, 2019

Mark Adams
Chief Executive Officer
Jacksam Corp
30291 Avenida de Las Banderas, Suite B
Rancho Santa Margarita, CA 92688

       Re: Jacksam Corp
           Registration Statement on Form S-1
           Amended on January 15, 2019
           File no. 333-228422

Dear Mr. Adams:

      We have reviewed your amended registration 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 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. Unless
we note
otherwise, our references to prior comments are to comments in our December 11,
2018, letter.

Registration Statement on Form S-1/A, filed on January 15, 2019

Summary Compensation Table, page 44

1.     Please update your disclosures as of December 31, 2018.
Plan of Distribution, page 50

2.     We note your response to prior Comment 12. Please revise to clarify how
the
       determinations of daily volume and sales price will be made. Also,
please add clarifying
       disclosure within this section of your prospectus similar to that found
in the second
       paragraph of your response, addressing the company's ability to waive
volume and price
       limits.
 Mark Adams
Jacksam Corp
February 7, 2019
Page 2
Financial Statements
Note 2: Significant Accounting Policies
Revenue Recognition, page F-22

3.     We note your response to prior comment 15 and your disclosures here, and
on page 24,
       regarding the adoption of ASC 606. Please tell us how you considered the
disclosure
       guidance set forth in ASC 606-10-50 (e.g. explanations of your
performance obligations,
       transaction price allocated to remaining performance obligations,
significant judgments
       applied, determining the timing of satisfaction of each performance
obligation, election of
       practical expedients, etc.).
Note 7: Accrued Liabilities -- Other, page F-29

4.     We note your response to prior comment 16. Please revise your
disclosures to better
       explain the facts and circumstances relating to the "Hua Hui" and
"Redrock" liabilities,
       including that currently there appears to be no written agreements in
place governing the
       terms of the loans, why current management determined the liabilities
could not be
       extinguish in accordance with ASC 405-20-40, and whether or not, and
why, you are
       accruing interest in accordance with the prior disclosed terms of the
loans.
        You may contact Joseph Cascarano, Staff Accountant, at 202-551-3376, or
Robert
Littlepage, Accounting Branch Chief, at 202-551-3361, if you have questions
regarding
comments on the financial statements and related matters. Please contact Paul
Fischer, Staff
Attorney, at 202-551-3415, or Larry Spirgel, Assistant Director, at
202-551-3815, with any
other questions.



                                                            Sincerely,
FirstName LastNameMark Adams
                                                            Division of
Corporation Finance
Comapany NameJacksam Corp
                                                            Office of
Telecommunications
February 7, 2019 Page 2
cc:       Bryan Clark
FirstName LastName