May 2, 2019

Patrick Herguth
Chief Executive Officer
MYnd Analytics, Inc.
26522 La Alameda
Suite 290
Mission Viejo, CA 2

       Re: MYnd Analytics, Inc.
           Form 10-K for the Year Ended September 30, 2018
           Form 10-Q for the Quarterly Period Ended December 31, 2018
           File No. 001-35527

Dear Mr. Herguth:

       We have reviewed your filing 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 providing
the requested
information or advise 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 September 30, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Financial Operations Overview for the Fiscal Year Ended September 30, 2018 and
2017
Revenues, page 49

1.    Please revise to provide a robust discussion explaining the specific
reasons and factors
      contributing to material increases in neurometric services revenues and
telepsychiatry
      services revenues during the periods presented.
 Patrick Herguth
FirstName LastNamePatrick Herguth
MYnd Analytics, Inc.
Comapany NameMYnd Analytics, Inc.
May 2, 2019
May 2, 2019 Page 2
Page 2
FirstName LastName
Financial Statements
Notes to Consolidated Financial Statements
2. Summary of Significant Accounting Policies
Variable Interest Entities (VIE), page 68

2.       We note that during the fiscal year 2018 Arcadian Services entered
into management and
         service agreements with four individual entities. We also note that
you consolidated these
         variable interest entities since you are the primary beneficiary.
Please tell us how you
         comply with the requirements to (a) present assets and liabilities of
the VIEs on the face
         of your consolidated balance sheets pursuant to ASC 810-10-45-25 and
(b) provide other
         VIE disclosures required by ASC 810-10-50. Revise your disclosures as
appropriate. In
         addition, please disclose the amount of retained earnings or net
income of VIEs that is
         restricted or free of restrictions for payment of dividends as
required by Rule 4-08(e)(1) of
         Regulation S-X.
6. Stockholders' Equity, page 77

3.       We note your disclosure here that you issued purchase notices to
Aspire Capital to
         purchase 1,180,000 and 884,671 common shares under the first and
second purchase
         agreements respectively. We also note that you issued 2.5 million
common shares to
         Aspire Capital for entering into the second purchase agreement. Please
reconcile the
         shares issued to Aspire Capital disclosed here to the statement of
changes in equity on
         page F-5 and revise your disclosures as appropriate.
Form 10-Q for the Quarterly Period Ended December 31, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations for Three Months Ended December 31, 2018 and 2017
Cost of Revenues, page 35

4.       We note that the cost of revenues for neurometric services represents
approximately 8%
         and 92% of neurometric services revenues for the three months ended
December 31, 2018
         and 2017 respectively, and approximately 50% of neurometric services
revenues for the
         year ended September 30, 2018. Please expand your discussion to
disclose the business
         reasons for the significant changes in cost of revenues relating to
neurometric services and
         telepsychiatry services during the periods presented.
        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.
 Patrick Herguth
MYnd Analytics, Inc.
May 2, 2019
Page 3

       You may contact Brian McAllister at (202) 551-3341 or Raj Rajan at (202)
551-3388 if
you have questions regarding comments on the financial statements and related
matters.



                                                         Sincerely,
FirstName LastNamePatrick Herguth
                                                         Division of
Corporation Finance
Comapany NameMYnd Analytics, Inc.
                                                         Office of Beverages,
Apparel and
May 2, 2019 Page 3                                       Mining
FirstName LastName