May 17, 2019

Bradley Robinson
Chief Executive Officer
Predictive Technology Group, Inc.
2749 Parleys Way, Suite 101
Salt Lake City, UT 84019

       Re: Predictive Technology Group, Inc.
           Registration Statement on Form 10-12G
           Filed December 6, 2018
           File No. 000-56008

Dear Mr. Robinson:

       We have reviewed your filing 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 these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

     After reviewing your response and any amendment you may file in response
to these
comments, we may have additional comments.

Form 10-12G/A filed on April 22, 2019

Consolidated Statement of Operations, page F-3

1.    We have read your response to comment ten. Your response addresses
amortization
      expense related to Renovo Biotech; however, it appears that you also
recorded
      amortization expense for several other intangible assets including the
Juneau license
      agreement and other trade secrets acquired in the periods presented. As
such, please tell
      us what consideration was given to including this expense within cost of
revenues
      considering some of your intangible assets appear to be related to
revenue generating
      activities. Refer to Rule 5-03(b)(2) of Regulation S-X and SAB Topic
11:B.
 Bradley Robinson
Predictive Technology Group, Inc.
May 17, 2019
Page 2
Notes to Condensed Consolidated Financial Statements
Note 1 Business Description and Significant Accounting Policies
Consolidation , page F-8

2.       Your consolidation policy indicates that your financial statements
include the financial
         statements of Predictive Technology Group, Inc. and its wholly owned
subsidiaries.
         Please also identify any subsidiaries which are included in your
financial statements that
         are not 100% owned and how you account for such subsidiaries.
Note 6 Variable Interest Entities, page F-18

3.       We note your response to comment 11 which indicates that you increased
your ownership
         in Juneau to approximately 51% and the disclosures in your filing
which indicate that you
         currently own 49.6% of Juneau. Please tell us when and how you
acquired the additional
         ownership in Juneau which gave you approximately 51% ownership. And,
please tell us
         how you are accounting for this investment.
        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.

        You may contact Mindy Hooker, Staff Accountant, at 202-551-3732 or John
Cash,
Accounting Branch Chief, at 202-5513768 if you have questions regarding
comments on the
financial statements and related matters. Please contact Kate McHale, Staff
Attorney, at 202-
551-3464 or Jay Ingram, Legal Branch Chief, at 202-551-3397 with any other
questions.



                                                               Sincerely,
FirstName LastNameBradley Robinson
                                                               Division of
Corporation Finance
Comapany NamePredictive Technology Group, Inc.
                                                               Office of
Manufacturing and
May 17, 2019 Page 2                                            Construction
FirstName LastName