August 15, 2024

Steven Shum
Chief Executive Officer
INVO Bioscience, Inc.
5582 Broadcast Court
Sarasota, Florida 34240

       Re: INVO Bioscience, Inc.
           Correspondence Dated July 31, 2024
           Registration Statement on Form S-3 Filed May 21, 2024
           File No. 333-279593
Dear Steven Shum:

       We have reviewed your July 31, 2024 response to our comment letter and
have the
following comment.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe a comment applies 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 registration statement and the
information you
provide in response to this letter, we may have additional comments. Unless we
note otherwise,
any references to prior comments are to comments in our July 18, 2024 letter.

Registration Statement on Form S-3, Correspondence Dated July 31, 2024
Incorporation of Certain Documents by Reference, page 2

1.     We have read your response to prior comment 1 and reissue in part. We
understand that
       your proposal is to amend your filings to disclose to investors that in
applying your lease
       accounting you are using the Federal government   s borrowing rate which
you determined
       to have the same effect as using the Registrant   s incremental
borrowing rates. One
       outcome of this proposal is that your December 31, 2023 total assets
appear to be
       overstated by approximately 8%. Given the impact of this error on your
total assets, it is
       not clear how you reasonably concluded that the corresponding financial
statement
       account balances should not be consistent with the applicable discount
rates required by
       GAAP. Please revise the financial statement balances to be consistent
with the applicable
       GAAP requirements. Alternatively, please provide us an expanded analysis
that includes
       all applicable calculations and a quantified reconciliation between your
assumed 2023
 August 15, 2024
Page 2

       incremental borrowing rates and your actual 2023 borrowing rates as
previously
       requested. In this regard, it appears that your actual borrowing rates
may be a more
       objective and reliable source of evidence in estimating your 2023
incremental borrowing
       rate. We may have further comment.
       Please contact Robert Augustin at 202-551-8483 or Katherine Bagley at
202-551-2545
with any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Industrial
Applications and
                                                          Services
cc:   Marc Indeglia