December 20, 2018

Don D'Ambrosio
Chief Financial Officer
MYnd Analytics, Inc.
26522 La Alameda, Suite 290
Mission Viejo, CA 92691

       Re: MYnd Analytics, Inc.
           Registration Statement on Form S-1
           Filed December 14, 2018
           File No. 333-228834

Dear Mr. D'Ambrosio:

       This is to advise you that we have not reviewed and will not review your
registration
statement.

        Please refer to Rules 460 and 461 regarding requests for acceleration.
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.

       Please contact Ruairi Regan at (202) 551-3269 with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Beverages, Apparel and
                                                            Mining
cc:    Jeffrey A. Baumel, Esq.