SecProbe.io

Mail Stop 3030
October 1 8, 2017

Matthew N. Wolfson
Chief Executive Officer
Electromedical Technologies, Inc.
16561 N 92nd Street, Suite 101
Scottsdale, AZ 85260

Re: Electromedical Technologies, Inc.
Offering Statement  on Form 1-A
Filed September 20, 2017
File No. 024 -10743

Dear Mr. Wolfson :

 We have reviewed your offering 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 offering statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do no t believe an amendment is appropriate, please tell us why in your
response.  After reviewing any amendment to your offering statement and the information you
provide in response to these comments, we may have additional comments.

Part II – Offering Circular

1. Disclose, for each covered product, the indications for use specified in your FDA
certification.

Plan of Distribution and Selling Shareholders, page 16

2. We note your disclosure in the third paragraph on page 17 about your website.  Indicate
how you will sell the securities via your website , including identifying any broker -dealer s
involved or the exemption from broker -dealer registration the selling party intends to rely
upon.

3. We note you have provided credits towards purchases of stock in this offering, as
indicated on pages 18 and F -16.  Please tell us how issuance of the credits and,
separately, issuance of shares to in this offering in exchange for those credits complies
with the requirements of Section 5 of the Securities Act of 1933 .

Matthew N. Wolfson
Electromedical Technologies, Inc.
October 18, 2017
Page 2

 Offering Perks, page 19

4. We note that you reserve the right to terminate the offer investment packages at any time
during the offering.  Please disclose the manner in which you intend to notify investors
that you have terminated the packages.   In addition,  address any regulatory implications.
By way of example only, how will you ensure prescriptions for the WellnessPro Plus
unit?  Explain the basis for the market values indicated.

Strategy, page 25

5. Please tell us the authority on which you rely to refer investors to testimonials on your
website as you do in the first paragraph of this section.

We will consider qualifying your offering statement at your request.  If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding an y review, comments, action or absence of
action by the staff.  We also remind you that, following qualification of your Form 1 -A, Rule 257
of Regulation  A requires you to file periodic and current reports, including a Form 1 -K which
will be due within 120 calendar days after the end of the fiscal year covered by the report.

Please contact Tom Jones at (202) 551 -3602 or me at (202) 551 -3528 with any questions.

Sincerely,

 /s/ Amanda Ravitz

Amanda Ravitz
Assistant Director
Office of Electronics and  Machinery

cc: Jamie Ostrow