May 16, 2025

Robert Lim
Chief Executive Officer
iSpecimen Inc.
8 Cabot Road, Suite 1800
Woburn, MA 01801

       Re: iSpecimen Inc.
           Registration Statement on Form S-1
           Filed May 2, 2025
           File No. 333-286958
Dear Robert Lim:

       We have conducted a limited review of your registration statement and
have the
following comments.

        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.

Registration Statement on Form S-1 filed May 2, 2025
Prospectus Summary, page 1

1.     We note you expect to receive $2,770,000 in net proceeds from this
offering and you
       intend to use approximately $1,000,000 of the net proceeds to fund the
initial
       milestone payment to Sales Stack Solutions Corp. "for the acquisition,
integration,
       and maintenance of the SalesStack technology platform." We note Section
6 of the
       term sheet with Sales Stack Solutions Corp., filed as Exhibit 10.46,
states: "this Term
       Sheet is intended as a statement of mutual intentions and does not
constitute a binding
       obligation on either party. Binding obligations will arise only upon the
execution and
       delivery of the definitive agreement." Please revise the prospectus to
discuss the
       material terms of this term sheet and please disclose clearly if there
are any risks
       stemming from the non-binding nature of this term sheet. If there are
risks, please
       revise to discuss the potential consequences if the definitive agreement
is not executed
 May 16, 2025
Page 2

       and delivered. Additionally, we note you intend to use approximately
$1,000,000 of
       the net proceeds for "marketing and advertising services" to be provided
by IR
       Agency LLC. Please expand your disclosure here to discuss the material
terms of this
       agreement. Finally, disclose if either party is a related party pursuant
to Item 404 of
       Regulation S-K.
Use of Proceeds, page 12

2.     We note the sensitivity analysis provided in the use of proceeds table.
Given this is a
       firm commitment offering, please explain to us why you included a
sensitivity
       analysis. Please also revise the table to depict the use of proceeds
that the Company
       states the intended uses are for. Specifically, we note your disclosure
on page 12 that
       the intended uses are for "approximately $1,000,000 of the net proceeds
for marketing
       and advertising services to be provided by IR Agency LLC,"
"approximately
       $1,000,000 of the net proceeds to fund the initial milestone payment to
Sales Stack
       Solutions Corp., a British Columbia company, pursuant to a signed term
sheet for the
       acquisition, integration, and maintenance of the SalesStack technology
platform," and
       the "remaining net proceeds will be used for working capital and general
corporate
       purposes." Therefore, it is unclear why you list other and more general
uses of
       proceeds in this table.
Incorporation of Certain Information by Reference, page 23

3.     Please revise to incorporate by reference each of the current reports on
Form 8-K
       required pursuant to Item 12(a)(2) of Form S-1, which requires
incorporation by
       reference of all current reports filed pursuant to Section 13(a) or
15(d) of the
       Exchange Act since the end of the fiscal year covered by the
registrant's latest annual
       report on Form 10-K.
Signatures, page II-10

4.     Instruction 1 to Signatures on Form S-1 requires, in relevant part, that
the registration
       statement is signed by the company's principal financial officer,
controller or principal
       accounting officer. If the person who performs the functions of your
principal
       financial officer, controller or principal accounting officer currently
has a signature
       line on the registration statement, please revise the corresponding
parenthetical
       descriptor under the Title column to indicate that such person is, or
also is, signing in
       the capacity of your principal financial officer, controller or
principal accounting
       officer. We note that the certification of your "Principal Financial
Officer" filed as
       Exhibit 31.2 to your Form 10-K for the year-ended December 31, 2024, was
signed by
       Yuying Liang, who has not signed this registration statement, as your
"Principal
       Accounting and Financial Officer."
 May 16, 2025
Page 3

        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

      Please contact Nicholas O'Leary at 202-551-4451 or Margaret Sawicki at
202-551-
7153 with any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Industrial
Applications and
                                                           Services
cc:   Ross Carmel, Esq.