SecProbe.io

August 14, 2018
Amro Albanna
Chief Executive Officer
ADiTx Therapeutics, Inc.
11161 Anderson St., Suite 105-10014
Loma Linda, CA 92354
Re:ADiTx Therapeutics, Inc.
Amendment No. 4 to Offering Statement on Form 1-A
Filed on August 7, 2018
File No. 024-10825
Dear Mr. Albanna:
            We have reviewed your amended 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 not 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.
Offering Statement on Form 1-A
General
1.We note the disclosure that you will not consummate the offering if your common stock is
not listed on the Nasdaq Capital Market.  Please clarify if you are applying to have the
Units listed as well.  Please also explain when shareholders are able to separately trade the
common stock and warrants included in the Units.

 FirstName LastNameAmro Albanna
 Comapany NameADiTx Therapeutics, Inc.
 August 14, 2018 Page 2
 FirstName LastName
Amro Albanna
ADiTx Therapeutics, Inc.
August 14, 2018
Page 2

Summary
Best Efforts, page 7
2.Please clarify here that he Underwriter is offering the Units on a best efforts basis, or
advise.
            You may contact Abe Friedman at (202) 551-8298 or Jean Yu at (202) 551-3305 if
you have questions regarding comments on the financial statements and related matters.
Please contact Tonya K. Aldave at (202) 551-3601 or Susan Block at (202) 551-3210 with any
otherquestions.
Sincerely,
Division of Corporation Finance
Office of Transportation and Leisure
cc:       Richard Friedman, Esq.