October 24, 2018

Edward Cox
Chief Executive Officer
Dthera Sciences
7310 Miramar Rd., Suite 350
San Diego, CA 92126

       Re: Dthera Sciences
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed April 2, 2018
           Form 10-Q for the Fiscal Quarter Ended June 30, 2018
           Filed August 14, 2018
           File No. 333-191175

Dear Mr. Cox:

       We have reviewed your filings 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 these comments within ten business days by amending
your Form 10-K
or by advising us as soon as possible when you will respond. If you do not
believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2017

Business, page 1

1.    Please disclose whether you have sold any ReminX products and whether you
have
      generated a material amount of revenue from these sales. Please also
provide context to
      your products discussion here and throughout your filing by disclosing
that
      commercialization of ReminX has only just begun.
2.    We note your statement that "[a]dditional products are under development
that are
      expected to directly target the symptoms of Alzheimer's disease and other
dementias, such
      as anxiety, depression, and cognitive decline, and for which Company may
seek FDA
      clearance or approval as well as reimbursement." For context, please
provide more
 Edward Cox
FirstName LastNameEdward Cox
Dthera Sciences
Comapany NameDthera Sciences
October 24, 2018
Page 2
October 24, 2018 Page 2
FirstName LastName
         disclosures regarding the FDA approval process, the costs associated
with that process,
         and the anticipated timeframe for necessary approvals. Discuss the
clinical trials process
         and the company's current clinical and business development plans.
Other Therapeutic Uses, page 5

3.       You state that you are "exploring other applications of the platform
targeting other
         indications..." Describe what these indications are.
Government Regulation, page 7

4.       You state that there "may be other healthcare-related laws and
regulations that will
         become applicable" to the company if the company pursues the
development of an FDA
         approved device. Provide more detail regarding what laws and
regulations would be
         specifically applicable.
Security Ownership of Certain Beneficial Owners and Management and Related
Stockholder
Matters, page 38

5.       We note your disclosure that RSJ Investments beneficially owns 6.23%
of your common
         stock. Please revise to identify the natural person(s) with voting and
investment power
         over the shares held by RSJ Investments.
Form 10-Q for the Quarter Ended June 30, 2018

Condensed Consolidated Balance Sheets, page 3

6.       Please provide detailed footnote disclosure within your interim period
financial
         statements in support of the prepaid expense amount reported as of
June 30, 3018.
Note 5- Computer Software Development Costs, page 9

7.       In light of the nature of your research and development activities,
please explain to us why
         you reference in your policy note ASC 350-40 and not the guidance in
ASC 985-20. Also,
         if applicable to your capitalized computer software development costs,
please explain to
         us in detail how you met the conditions in ASC 985-20-25-4 for
capitalization.
        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.
 Edward Cox
Dthera Sciences
October 24, 2018
Page 3

       You may contact Kathryn Jacobson, Senior Staff Accountant, at (202)
551-3365 or
Robert S. Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have
questions
regarding comments on the financial statements and related matters. Please
contact William
Mastrianna, Attorney-Adviser, at (202) 551-3778 or Celeste M. Murphy, Legal
Branch Chief, at
(202) 551-3257 with any other questions.



                                                         Sincerely,
FirstName LastNameEdward Cox
                                                         Division of
Corporation Finance
Comapany NameDthera Sciences
                                                         Office of
Telecommunications
October 24, 2018 Page 3
cc:       Park Lloyd
FirstName LastName