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                              December 16, 2021

       Mala Murthy
       Chief Financial Officer
       Teladoc Health, Inc.
       2 Manhattanville Road, Suite 203
       Purchase, New York 10577

                                                        Re: Teladoc Health,
Inc.
                                                            Form 10-K for
Fiscal Year Ended December 30, 2020
                                                            Filed March 1, 2021
                                                            File No. 001-37477

       Dear Ms. Murthy:

              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 to these comments, we may have additional comments.

       Form 10-K for Fiscal Year Ended December 30, 2020

       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Critical Accounting Policies
       Business Combinations, page 60

   1.                                                   We note for the Livongo
acquisition that you allocated the customer relationships
                                                        intangible asset a fair
value of $1.05 billion. In the Form S-4 pro forma financial
                                                        information, the
estimated useful life was 7.5 years. However, it appears that the
                                                        estimated useful life
significantly increased with the preliminary accounting for the
                                                        merger in the
consolidated financial statements. Finally, we note that Livongo has been
                                                        providing its chronic
illness services since 2014, or six years before the merger. Please
                                                        disclose the estimated
useful life of the customer relationships intangible asset, how the
                                                        useful life was
estimated, including the material factors considered that are specific to
                                                        Livongo, and what
additional information was obtained subsequent to the Form S-4 that
                                                        significantly increased
the number of years over which the asset is amortized.
 Mala Murthy
Teladoc Health, Inc.
December 16, 2021
Page 2
Technology and Development Expenses, page 62

2.       Please tell us the amount of direct technology expenses related to
revenue included in the
         technology and development expenses line item, as well as the amount
related to research
         and development activities. Tell us how you considered whether such
amounts should be
         separately reported on your Consolidated Statements of Operations.
        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 Tracey Houser at 202-551-3736 or Terence O'Brien at
202-551-3355, if
you have questions regarding comments on the financial statements and related
matters.



FirstName LastNameMala Murthy                                 Sincerely,
Comapany NameTeladoc Health, Inc.
                                                              Division of
Corporation Finance
December 16, 2021 Page 2                                      Office of Life
Sciences
FirstName LastName