EX-19

You should read this Policy address questions to the General Counsel of Emmaus Life Sciences, Inc. (formerly known as MYnd Analytics, Ince) and return the attached acknowledgement to Human Resources.

Emmaus Life Sciences, Inc. including its subsidiaries and affiliates (collectively “Emmaus Life Sciences”) has adopted a policy on insider trading that applies to each officer, director and employee of Emmaus Life Sciences. A policy has been distributed to all officers, directors and employees. Under Emmaus Life Sciences’ insider trading policy, each officer, director and employee of Emmaus Life Sciences is forbidden from:

(i)

trading in securities of Emmaus Life Sciences (or in puts and calls for Emmaus Life Sciences securities) on the basis of information that is material and nonpublic;

While the general Policy on Insider Trading applies to all directors, officers and employees of Emmaus Life Sciences, its subsidiaries and affiliates, the Board of Directors believes it is appropriate that transactions in Emmaus Life Sciences securities by directors, officers and employees (who may, by virtue of their duties or work conditions, have regular access to material nonpublic information concerning Emmaus Life Sciences) of Emmaus Life Sciences and its significant subsidiaries be subject to certain additional restrictions in order to reduce the risk of securities law violations. The Policy Regarding Special Trading Procedures contains a discussion of insider trading and describes the special trading restrictions applicable to directors, officers and employees (who may, by virtue of their duties or work conditions, have regular access to material nonpublic information concerning Emmaus Life Sciences) of Emmaus Life Sciences and its significant subsidiaries. You must read, sign and retain a copy of this policy and, upon request by Emmaus Life Sciences, re-acknowledge it.

Insider trading is, in addition to being a violation of Emmaus Life Sciences’ policy, a violation of securities laws. The penalties for insider trading are discussed below.

The term "insider trading" generally is used to refer to the use of material, nonpublic information to trade in securities or to communications of material, nonpublic information to others who may trade on the basis of such information.

While the law concerning insider trading is not static, it is generally understood that the law prohibits insiders of Emmaus Life Sciences from doing the following:

Trading in Emmaus Life Sciences' securities while in possession of material, nonpublic information concerning Emmaus Life Sciences.

Having others trade on the insider's behalf while he or she is in possession of material, nonpublic information.

Communicating nonpublic information concerning Emmaus Life Sciences to others who may then trade in Emmaus Life Sciences’ securities or pass on the information to others who may trade in Emmaus Life Sciences’ securities. Such conduct, also known as "tipping," results in liability for the insider of Emmaus Life Sciences who communicated such information, even if such insider does not actually trade himself, and for the person who received the information if the person has reason to know that it was an improper disclosure and acts on such information or passes it on to others who may act on it.

The elements of insider trading and the potential penalties for such unlawful conduct are discussed below.

The concept of "insider" generally includes any person who possesses nonpublic information about Emmaus Life Sciences and who has a duty to Emmaus Life Sciences to keep this information confidential. In the case of Emmaus Life Sciences, "insiders" include officers and directors of Emmaus Life Sciences and officers and directors of Emmaus Life Sciences’ subsidiaries, as well as employees of any of such entities who routinely have access to material information that is not publicly available or who are working on significant corporate transactions or projects. In addition, a person can be a "temporary insider" if he or she enters into a relationship to serve Emmaus Life Sciences and as a result is given access to information in connection with such service. Outsiders who can become temporary insiders include, among others, Emmaus Life Sciences’ attorneys, accountants, consultants, advisory board members, investment bankers and the employees of such organizations.

"Material Information" generally is defined as information for which there is a substantial likelihood that a reasonable investor would consider such information important in making his or her investment decisions, or information that is reasonably certain to affect the price of a company's securities. It is important to remember that materiality will always be judged with the benefit of hindsight.

Although there is no precise definition of materiality, information is likely to be "material" if it relates to:

"Inside" information could be material because of its expected effect on the price of Emmaus Life Sciences’ securities, the securities of another company, or the securities of several companies. Moreover, the resulting prohibition against the misuse of "inside" information includes not only restrictions on trading in Emmaus Life Sciences’ securities but restrictions on trading in the securities of other companies affected by the inside information.

In order for information to qualify as "inside" information it must not only be "material," it must be "nonpublic." "Nonpublic" information is information which has not been made available to investors generally. This includes information received from sources or in circumstances indicating the information has not yet been generally circulated.

At such time as material, nonpublic information has been released to the investing public, it loses its status as "inside" information. However, for "nonpublic" information to become public information it must be disseminated through recognized channels of distribution designed to reach the securities marketplace, and sufficient time must pass for the information to become available in the market.

To show that "material" information is public, it is generally necessary to point to some fact verifying that the information has become generally available, such as disclosure by filing of a Form 10-Q, Form 10-K, Form 8-K or other report with the Securities and Exchange Commission or disclosure by press release to a national business and financial wire service (such as Dow Jones or Reuters), a national news service, or a national newspaper (such as The Wall Street Journal). The circulation of rumors or "talk on the street," even if accurate, widespread and reported in the media, does not constitute the requisite public disclosure.

Material, nonpublic information is not made public by selective dissemination. Material information improperly disclosed only to institutional investors or to a favored analyst or a group of analysts retains its status as "nonpublic" information, the use of which is subject to insider trading laws. Similarly, partial disclosure does not constitute public dissemination. So long as any material component of the "inside" information has yet to be publicly disclosed, the information is deemed "nonpublic" and may not be misused.

It is the policy of Emmaus Life Sciences to not consider material information public until the third business day after appropriate public dissemination.

The purchase or sale of Company Securities while aware of Material Non-Public Information, or the disclosure of Material Non-Public Information to others who then trade in Company Securities, is prohibited by federal and state laws. Insider trading violations are pursued vigorously by the SEC, U.S. Attorneys and state enforcement authorities. Punishment for insider trading violations is severe, and could include significant fines and imprisonment. While the regulatory authorities concentrate their efforts on the individuals who trade, or who tip inside information to others who trade, the federal securities laws also impose potential liability on companies and other “controlling persons” if they fail to take reasonable steps to prevent insider trading by company personnel. In addition, an individual’s failure to comply with this Policy may subject the individual to Company-imposed sanctions, including dismissal for cause, whether or not the employee’s failure to comply results in a violation of law. Needless to say, a violation of law, or even an SEC investigation that does not result in prosecution, can tarnish a person’s reputation and irreparably damage a career.

In addition, a violation of this policy statement can be expected to result in serious sanctions by Emmaus Life Sciences, which may include dismissal of the person involved.

The following Special Trading Policies are applicable to you because you are a director or an officer of Emmaus Life Sciences or its significant subsidiaries or an employee of Emmaus Life Sciences or its significant subsidiaries who may, by virtue of your duties or work conditions, have regular access to material nonpublic information concerning Emmaus Life Sciences.

From time to time, an event may occur that is material to Emmaus Life Sciences and is known by only a few directors or executives. So long as the event remains material and nonpublic, the persons who are aware of the event, as well as other persons covered by these Special Trading Procedures, may not trade in Emmaus Life Sciences’ securities, as follows. The existence of an event-specific blackout will not be announced, other than it may be announced to those who are aware of the event giving rise to the blackout. If, however, a person whose trades are subject to pre-clearance requests permission to trade in Emmaus Life Sciences’ securities during an event-specific blackout, Emmaus Life Sciences’ General Counsel will inform the requesting person of the existence of a blackout period, without disclosing the reason for the blackout. Any person made aware of the existence of an event-specific blackout should not disclose the existence of the blackout to any other person. The failure of Emmaus Life Sciences' General Counsel to designate a person as being subject to an event-specific blackout will not relieve that person of the obligation not to trade while aware of material nonpublic information.

The Securities and Exchange Commission has established regulations under which individuals may purchase and sell securities in compliance with "insider trading" laws (more specifically, Rule 10b5-l of the Securities Exchange Act of 1934) if such purchases or sales are made pursuant to (i) a binding contract to purchase or sell the security, (ii) instructions provided to a third person to execute the trade for the instructing person or entity's account or (iii) an adopted written plan for trading securities; provided, that at the time of the decision to enter into such contract or plan or decision to provide such instructions, you were not aware of material, nonpublic information. In addition to other requirements set forth in such regulations, the contact instructions or plan must (a) specify the amount, price and date of the purchase or sale or (b) provide a written formula or algorithm or computer program for determining the amounts, prices and dates of such purchases or sales.

Under Emmaus Life Sciences’ policy, you, your spouse and members of your immediate family sharing the same household may onlv enter into a contract or plan or provide instructions for the purchase or sell securities of Emmaus Life Sciences in compliance with these regulations after receiving written pre-clearance of trading from Emmaus Life Sciences’ General Counsel.

There are a number of issues that you must consider prior to adopting a contract or plan or providing instructions for the purchase or sale of Emmaus Life Sciences’ securities that complies with these newly established regulations. As a result you are advised to contact Emmaus Life Sciences’ General Counsel if you, your spouse or any member of your immediate family sharing the same household is considering adopting such contract or plan or providing such instructions for the purchase or sale of Emmaus Life Sciences’ securities. In the event that either you, your spouse or members of your immediate family sharing the same household adopts a contract or plan or provides the instructions discussed above, a copy of such document must be delivered to Emmaus Life Sciences’ General Counsel prior to any sales or purchases of Emmaus Life Sciences’ Securities.

Certain private transactions may not involve insider trading if both parties have equal access to information. For instance, a purchase and sale between two directors would generally not involve insider trading if both directors have access to the same information about Emmaus Life Sciences. Any private transaction may only be undertaken, however, if pre-approved in writing by Emmaus Life Sciences’ General Counsel or Chief Financial Officer.

You are required to report to Emmaus Life Sciences’ General Counsel any transaction in securities of Emmaus Life Sciences by you, your spouse, or any immediate family member sharing your household not later than the business day following the date of your transaction. Each report you make to Emmaus Life Sciences’ General Counsel should include the date of the transaction, quantity, price, and broker through which the transaction was effected. This reporting requirement may be satisfied by sending (or having your broker send) duplicate confirmations of trades to Emmaus Life Sciences’ General Counsel if such information is received by the required date.

The foregoing reporting requirement is designed to help monitor compliance with the Special Trading Procedures set forth herein and to enable Emmaus Life Sciences to help those persons who are subject to reporting obligations under Section 16 of the Securities Exchange Act of 1934 to comply with such reporting obligations. Each officer and director, however, and not Emmaus Life Sciences, is personally responsible for ensuring that his or her transactions do not give rise to "short swing" liability under Section 16 and for filing timely reports of transactions with the Securities and Exchange Commission.

Even if you receive preclearance and it is during a trading window, you, your spouse and any member of your immediate family sharing your household may not trade in securities of Emmaus Life Sciences if you are in possession of material, nonpublic information about Emmaus Life Sciences. The procedures set forth herein are in addition to the general insider trading policy and are not a substitute therefore.

Prohibition on Short Sales. Neither you, your spouse nor any immediate family member sharing your household may sell any securities of Emmaus Life Sciences that are not owned by such person at the time of the sale (a "short sale") including a "sale against the box" (a sale with delayed delivery).

Trading in Standardized Options. An "option" is the right either to buy or sell a specified amount or value of a particular underlying interest at a fixed exercise price by exercising the option before its specified expiration date. An option which gives a right to buy is a "call" option, and an option which gives a right to sell is a "put" option. Standardized options (which are so labeled as a result of their standardized terms) offer the opportunity to invest using substantial leverage and therefore lend themselves to significant potential for abusive trading on material inside information. Standardized options also expire soon after issuance and thus necessarily involve short-term speculation, even where the date of expiration of the option makes the option exempt from certain Securities and Exchange Commission restrictions.

The writing of a call or the acquisition of a put also involves a "bet against the company" and therefore presents a clear conflict of interest for you. As a result, neither you, your spouse nor any immediate family member sharing your household may trade in standardized options relating to Emmaus Life Sciences’ securities at any time.

Hedging Transactions. Certain forms of hedging or monetization transactions, such as zero-cost collars and forward sale contracts, allow "insiders" to lock in much of the value of his or her stock holdings, often in exchange for all or part of the potential for upside appreciation in the stock. These transactions allow "insiders" to continue to own the covered securities, but without the full risks and rewards of ownership. When that occurs, the "insiders" may no longer have the same objectives as Emmaus Life Sciences’ other shareholders. Therefore, neither you, your spouse nor any immediate family member sharing your household may engage in any such transactions.

Margin Accounts and Pledges. Securities held in a margin account may be sold by the broker without the customer's consent if the customer fails to meet a margin call. Similarly, securities pledged or hypothecated as collateral for a loan may be sold in foreclosure if the borrower defaults on the loan. Because a margin sale or foreclosure sale may occur at a time when you are aware of material nonpublic information or otherwise are not permitted to trade in Emmaus Life Sciences’ securities, neither you, your spouse nor any immediate family member sharing your household may hold Emmaus Life Sciences’ securities in a margin account or pledge Emmaus Life Sciences’ securities as collateral for a loan unless such transaction has been pre approved by Emmaus Life Sciences’ General Counsel or President and Chief Financial Officer.

This policy continues to apply to your transactions in Company securities even after you have terminated employment or other services to Emmaus Life Sciences or a subsidiary as follows: if you are aware of material nonpublic information when your employment or service relationship terminates, you may not trade in Company securities until that information has become public or is no longer material.

If you know or have reason to believe that Emmaus Life Sciences’ policy on insider trading or the Special Trading Procedures described above have been or may be violated, you should bring the actual or potential violation to the attention of Emmaus Life Sciences’ General Counsel.

Emmaus Life Sciences reserves the right to amend or modify the procedures set forth herein at any time. Waiver of any provision of this policy statement in a specific instance may be authorized in writing by Emmaus Life Sciences’ General Counsel (or his/her designee).

If you have any questions regarding Emmaus Life Sciences’ Insider Trading Policy or the Special Trading Procedures described above, you should contact Emmaus Life Sciences’ General Counsel.

I have read Emmaus Life Sciences, Inc. Policy on Insider Trading and the Policy Regarding Special Trading Procedures will continue to comply with the policies for as long as I am subject to them. I understand that, if I am an employee of Emmaus Life Sciences or one of its subsidiaries, my failure to comply in all respects with Emmaus Life Sciences’ policies, including the Statement of Company Policy on Insider Trading and the Special Trading Procedures set forth herein, may lead to disciplinary action, including dismissal of my employment from Emmaus Life Sciences and any subsidiary thereof to which my employment now relates or may in the future relate.

This document states a policy of Emmaus Life Sciences, Inc., and is not intended to be regarded as the rendering of legal advice. This policy statement is intended to promote compliance with existing law and is not intended to create or impose liability that would not exist in the absence of the policy statement.