December 13, 2019 Christopher Nelson President and General Counsel Q2Earth Inc. 20 Royal Palm Way, Suite 100 Palm Beach, FL 33480 Re: Q2Earth Inc. Preliminary Proxy Statement on Schedule 14A Filed November 5, 2019 File No. 000-55148 Dear Mr. Nelson: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Joel Mayersohn, Esq.