SecProbe.io

CORRESP
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6450 Cameron Street

Suite
113

Las
Vegas, Nevada 89118

February
22, 2022

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Life Sciences

100
F Street, N.E.

Washington,
DC 20549

  Attention:
  Robyn
  Manuel

  Adam
  Phippen

    Re:

    Digipath,
    Inc.

    Form
    10-K for the Fiscal Year Ended September 30, 2021

    Filed
    December 29, 2021

    File
    No. 000-54239

Ladies
and Gentlemen:

This
letter is being submitted to the Securities and Exchange Commission (the “SEC”) by Digipath, Inc. (the “Company”),
in response to the comments of the staff (the “Staff”) of the Securities SEC contained in its letter dated February
8, 2022 (the “Comment Letter”), relating to the above referenced Annual Report on Form 10-K (the “10-K”).
In this letter, we have recited the Staff’s comments in italicized, bold type, followed by our response.

Item
9A. Controls and Procedures

Evaluation
of Disclosure Controls and Procedures, page 19

1.
Please confirm your disclosure of an Evaluation Date of September 30, 2020 is a typographical error and the evaluation date was actually
September 30, 2021. In future filings, please ensure you use the correct Evaluation Date in your disclosures.

The
Company hereby confirms that the September 30, 2020 Evaluation Date in the 10-K was a typographical error, and that the actual Evaluation
Date was September 30, 2021. The Company undertakes to use the correct Evaluation Date in future filings.

U.S.
Securities and Exchange Commission

February 22, 2022

Page 2

2.
We note your disclosure of material weaknesses in internal control over financial reporting and we also note that the material weaknesses
pertain to the recognition and measurement of the financial statements. As such, please tell us the basis for management’s conclusion
that disclosure controls and procedures were effective. If this is a typographical or other error and management concluded disclosure
controls and procedures were not effective as of the Evaluation Date, please advise us of this fact and ensure you accurately disclose
management’s conclusions in future filings.

Management
has concluded that that the Company’s disclosure controls and procedures were not effective as of September 30, 2021, and the statement
to the contrary in the 10-K was in error. We note that the 10-Q filed by the Company on February 14, 2022 discloses that the Company’s
disclosure controls and procedures were not effective at the reasonable assurance level at December 31, 2021, and undertake to properly
reflect management’s conclusions in this regard in future SEC filings.

Management’s
Annual Report on Internal Control Over Financial Reporting, page 19

3.
Given your identification and disclosure of material weaknesses in internal control over financial reporting (ICFR), management is required
to conclude and state in its report that internal control over financial reporting is ineffective. Refer to Item 308(a)(3) of Regulation
S-K. Thus, please explain your disclosure that ICFR is effective as of the Evaluation Date. If your disclosure that ICRF was effective
is a typographical or other error and should have indicated that ICFR was ineffective, please advise us of this fact and in future filings
please ensure your conclusion regarding the effectiveness of ICFR is consistent with whether you have identified material weaknesses
in ICFR.

Management
has concluded that that the Company’s internal control over financial reporting was not effective as of September 30, 2021 due
to the material weaknesses disclosed in the 10-K, and the statement to the contrary in the 10-K was in error. The Company undertakes
to properly disclose its conclusions regarding internal controls in future SEC filings.

    Very truly yours,

    DIGIPATH, INC.

    By:
    /s/ A.
    Stone Douglass

    A.
    Stone Douglass

    Chief
    Financial Officer