October 18, 2021




Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-3720


Attention:   Jordan Nimitz

Marijuana Co of America, Inc.
Offering Statement on Form 1-A

Filed October 1, 2021

File No. 024-11668

Qualification Request

Requested Date:   October 20, 2021

Requested Time:   4:00 P.M. Eastern Time


Dear Ms. Nimitz:


Pursuant to Rule 252(e) of Regulation A promulgated under the Securities Act of 1933, as amended, Marijuana Company of America, Inc. (the “Company”) hereby requests that the above-referenced offering statement on Form 1-A (File No. 024-11668) (the “Offering Statement”) be declared qualified at the “Requested Date” and “Requested Time” set forth above or at such later time as the Company or its counsel may orally request via telephone call to the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”). Once the Offering Statement has been qualified, please orally confirm that event with our counsel, Independent Law PLLC, by calling Alan T. Hawkins at (352) 353-4048.


In connection with the qualification request, the Company hereby acknowledges that:


    should the Commission or the Staff, acting pursuant to delegated authority, declare the Offering Statement qualified, it does not foreclose the Commission from taking any action with respect to the Offering Statement;


    the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing qualification, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Offering Statement; and


    the Company may not assert Staff comments and the declaration of qualification as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.







/s/ Jesus Quintero  

Name: Jesus Quintero

Title: Chief Financial Officer


cc:   Alan T. Hawkins, Esq.
Independent Law PLLC