February 7, 2019

Jeff Toghraie
Chief Executive Officer and Chief Financial Officer
Reviv3 Procare Co
9480 Telstar Avenue, Unit 5
El Monte, CA 90211

       Re: Reviv3 Procare Co
           Form 10-K for the fiscal year ended May 31, 2018
           File No. 333-220846

Dear Mr. Toghraie:

        We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. In our comment, we may ask you to
provide us
with information so we may better understand your disclosure.

       Please respond to this comment within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 10-K for the fiscal year ended May 31, 2018

Item 9A. Controls and Procedures, page 10

1.    We note management concluded that disclosure controls and procedures and
internal
      control over financial reporting were not effective as of May 31, 2018
due to the material
      weaknesses identified. We also note management concluded that disclosure
controls and
      procedures were effective as of November 30, 2018 and August 31, 2018 in
your Forms
      10-Q for the periods then ended but that there were no changes in
internal control over
      financial reporting during the interim periods. Please explain to us how
you determined
      the effectiveness of your disclosure controls and procedures changed from
period to
      period given that there were no changes in internal control over
financial reporting. It
      appears to us that you may need to amend your Forms 10-Q for the periods
ended
      November 30, 2018 and August 31, 2018 to either conclude that your
disclosure controls
      and procedures were not effective as of the interim dates or disclose and
discuss the
      changes in your internal control over financial reporting that resulted
in your disclosure
      controls and procedures being effective.
 Jeff Toghraie
Reviv3 Procare Co
February 7, 2019
Page 2


       In closing, 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 Mindy Hooker at 202-551-3732 or Anne McConnell at
202-551-3709
with any questions.



                                                          Sincerely,
FirstName LastNameJeff Toghraie
                                                          Division of
Corporation Finance
Comapany NameReviv3 Procare Co
                                                          Office of
Manufacturing and
February 7, 2019 Page 2                                   Construction
FirstName LastName