Hightimes Holding Corp.

10990 Wilshire Blvd., Penthouse

Los Angeles, CA 90024


July 19, 2018                       



U.S. Securities and Exchange Commission

100 F Street, N.E.

Mail Stop 3561

Washington, D.C. 20549

Att: Anne Nguyen Parker, Assistant Director

Office of Transportation and Leisure


  Re:   Hightimes Holding Corp.
    Offering Statement on Form 1-A
    Post-Qualification Amendment No. 1 filed June 12, 2018
    Post-Qualification Amendment No. 2 filed June 15, 2018

Post-Qualification Amendment No. 3 filed June 26, 2018

Post-Qualification Amendment No. 4 filed July 9, 2018

    File No. 024-10794


Dear Ms. Parker:


Reference is hereby made to the qualification request letter, dated July 19, 2018 (the “Qualification Request Letter”), seeking requalification of the above-referenced Offering Statement on Form 1-A POS, which was sent to the Securities and Exchange Commission (the “Commission”) on behalf of Hightimes Holding Corp., a Delaware corporation (the “Company” or “Hightimes”). On behalf of the Company, I hereby request withdrawal of the Qualification Request Letter.


Very truly yours,




By:   /s/ Adam E. Levin  
  Adam E. Levin, Chief Executive Officer  






Cc:   NMS Capital Advisors, LLC  
  CKR Law, LLP  
  Law Offices of Michelle Geller, Esq.