August 8, 2024

Jack Ross
Chief Executive Officer
Synergy CHC Corp.
865 Spring Street
Westbrook, ME 04092

       Re: Synergy CHC Corp.
           Amendment No. 1 to Registration Statement on Form S-1
           Filed July 29, 2024
           File No. 333-280556
Dear Jack Ross:

     We have reviewed your amended 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. Unless we
note otherwise,
any references to prior comments are to comments in our [Month day, year]
letter.

Amendment No. 1 to Form S-1
Our Company, page 1

1.     We note your revised disclosures in response to prior comment 10. To the
extent that you
       use the "clinically-tested" language in the opening paragraph it should
be clarified that
       this test was not a clinical trial conducted pursuant to an FDA-approved
IND application.
Summary, page 1

2.     With reference to prior comments 4 and 12, please revise the Summary,
where
       appropriate, to disclose the amount of debt that comes due in FY2024 and
FY2025 and
       indicate whether the company currently has plans to meet these
obligations.
Relationships with Knight Therapeutics, page 6

3.     We note your revised disclosure in response to prior comment 5. Please
further revise to
 August 8, 2024
Page 2

       highlight the existence of financial and operating covenants, including
the requirement
       that Knight approve your quarterly and annual operating budget prior to
implementation.
Use of Proceeds, page 29

4.     We note your revised disclosure in response to prior comment 11. As
revised, it appears
       that you currently do not have any specific plans for allocating the
offering proceeds. If
       so, then please provide the disclosure required by the second sentence
of Regulation S-K,
       Item 504. In light of your debt obligations, please also revise the
Summary to
       highlight the lack of current specific plans for the proceeds.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations for the Years Ended December 31, 2023 and December 31,
2022
Revenue, page 36

5.     We have read your response to prior comment 14 and note you expanded the
disclosure in
       your Business section to include FOCUSfactor revenue in fiscal years
ended December
       31, 2023 and 2022. As requested in our prior comment, please revise your
results of
       operations disclosure to break out the amount of net revenue by brand
for all periods
       presented. In addition to your disclosure of revenue by category in MD&A
on pages
       35 and 36, your disclosure should also include the revenue generated in
each period by the
       FOCUSfactor brand and the Flat Tummy brand, separately.
Certain Relationships and Related Party Transactions, page 72

6.     We note your revised disclosures in response to prior comment 19. Please
revise to
       explain what the BoomBod transactions were so it is clear what a "pass
through and
       allocation of expenses" is and why BoomBod owes the funds to you.
Clarify whether
       BoomBod is contractually obligated to make these payments to you by the
end of the year
       and whether any interest is owed on the debt. File as exhibits the
relevant agreements
       governing the obligations. Also, revise the prospectus, where
applicable, to explain
       whether you are relying upon repayment of the outstanding balance to
fund your
       operations and/or meet your near-term debt obligations. In addition,
revise the disclosure
       on page 59 to discuss Mr. Ross's role at BoomBod or advise.
       Please contact Tracie Mariner at 202-551-3744 or Vanessa Robertson at
202-551-3649 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Tamika Sheppard at 202-551-8346 or Joe McCann at 202-551-6262 with any
other
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Life
Sciences
cc:   Mike Bradshaw