April 30, 2019

Ryan Smith
Chief Executive Officer
Investview, Inc.
12 South 400 West
Salt Lake City, UT 84101

       Re: Investview, Inc.
           Amendment No. 5 to Registration Statement on Form S-1
           Filed April 17, 2019
           File No. 333-229341

Dear Mr. Smith:

      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 April 8,
2019 letter.

Amendment No. 5 to Registration Statement on Form S-1 filed April 17, 2019

Prospectus Summary, page 2

1.     We note your disclosure elsewhere in your filing that the shares covered
by the CSPA will
       be purchased at 85% of the lowest closing price of your common stock in
the five
       consecutive trading days immediately preceding the delivery of a
purchase notice to the
       Investor from you. Because the securities underlying the CSPA will be
issued based on a
       formula tied to your market price, please disclose the following on your
prospectus cover
       page: (1) the percentage of outstanding securities of the company the
shares represent,
       without giving effect to the conversion or exercise of any outstanding
convertible or
       exercisable securities; and (2) the current number of shares that the
investor may sell
       based on the current market price and ignoring any caps on the number of
shares that the
 Ryan Smith
Investview, Inc.
April 30, 2019
Page 2
       investor can own at any time.
Executive Compensation, page 28

2.     Please update your executive compensation to include the required
disclosure for the year
       ended March 31, 2019, your last completed fiscal year. See Item 402 of
Regulation S-K.
       Please contact Katherine Bagley, Staff Attorney, at (202) 551-2545 or
Mara Ransom,
Assistant Director, at (202) 551-3264 with any questions.



                                                           Sincerely,
FirstName LastNameRyan Smith
                                                           Division of
Corporation Finance
Comapany NameInvestview, Inc.
                                                           Office of Consumer
Products
April 30, 2019 Page 2
cc:       Kevin C. Timken
FirstName LastName