March 13, 2019

John A. Conklin
Chief Executive Officer
SolarWindow Technologies, Inc.
9375 East Shea Boulevard, Suite 107-B
Scottsdale, AZ 85260

       Re: SolarWindow Technologies, Inc.
           Post-Effective Amendment 1 to Registration Statement
           Filed February 28, 2019
           File No. 333-222809

Dear Mr. Conklin:

       We have reviewed your post-effective amendment and have the following
comments. In
some of our comments we may ask you to provide us information so that 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 that our comments apply to your
facts and
circumstances or do not believe that 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.

Post-Effective Amendment 1 to Registration Statement on Form S-1 filed February
28, 2019

General

1.     You indicate in the "Explanatory Note" on page 2 that the post-effective
amendment
       updates the financial statements for the fiscal year ended August 31,
2018. Since the
       filing of the updated financial statements was not timely, please advise
whether you have
       made any offers or sales using the prospectus during the period in which
the audited
       financial statements were not current.
2.     Disclosure on page 3 indicates that your common stock is quoted on
OTCPink. While
       issuers of securities quoted on OTCQX and OTCQB of OTC Markets may rely
upon our
       accommodations for at-the-market offerings by selling stockholders where
a public or
       existing market is necessary, those accommodations do not extend to
OTCPink. Please
       revise disclosure throughout the registration statement to indicate that
the shares of
 John A. Conklin
SolarWindow Technologies, Inc.
March 13, 2019
Page 2
         common stock being offered for sale by the selling stockholders will
be sold at a fixed
         price which you specify in the prospectus until your shares of common
stock are quoted
         on OTCQX or OTCQB or are listed on a national securities exchange or
are quoted on the
         OTCBB.
        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.

      You may contact Edward M. Kelly, Senior Counsel, at (202) 551-3728 or
Kathryn
McHale, Staff Attorney, at (202) 551-3464 with any questions about comments.



                                                            Sincerely,
FirstName LastNameJohn A. Conklin
                                                            Division of
Corporation Finance
Comapany NameSolarWindow Technologies, Inc.
                                                            Office of
Manufacturing and
March 13, 2019 Page 2                                       Construction
FirstName LastName