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                                December 30, 2020

       Mario Schlosser
       Chief Executive Officer
       Mulberry Health Inc.
       75 Varick Street, 5th Floor
       New York, NY 10013

                                                        Re: Mulberry Health
Inc.
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Submitted December
17, 2020
                                                            CIK No. 0001568651

       Dear Mr. Schlosser:

             We have reviewed your amended draft registration statement 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 this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Amendment No. 1 to Draft Registration Statement on Form S-1

       Hi, We are Oscar, page 1

   1.                                                   We note your response
to our prior comment 1 and reissue in part. Please disclose the
                                                        basis for your
statement that you are "the third largest for-profit national insurer in the
                                                        Individual market in
the United States based on membership."
       Summary Consolidated Financial and Other Data
       Key Operating and Non-GAAP Financial Metrics, page 11

   2.                                                   We note that you
present Adjusted InsuranceCo EBITDA. Please revise your disclosure
                                                        to reconcile to the
most directly comparable GAAP measure, consistent with Consolidated
                                                        Adjusted EBITDA. Refer
to Item 10(c)(1)(i)(B) of Regulation S-K.
 Mario Schlosser
FirstName LastNameMario   Schlosser
Mulberry Health Inc.
Comapany30,
December  NameMulberry
              2020        Health Inc.
December
Page 2    30, 2020 Page 2
FirstName LastName
3.       You disclose that Adjusted EBITDA helps you measure your core
operating performance
         over time by removing items that are not related to day-to-day
operations. You also state
         that Adjusted InsuranceCo EBITDA represents your revenue and expenses
for your core
         products. Considering that you only have one operating segment, please
revise your
         disclosures to more distinctly address how you define "core" operating
performance as
         measured by Adjusted EBITDA versus Adjusted InsuranceCo EBITDA revenue
and
         expenses from your "core" products.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Members by State, page 65

4.       We note your response prior comment 8. Considering you signed up
14,000 members in
         New York eight years ago which you highlight in your Letter from
Co-Founders, please
         enhance your discussion on page 66 to discuss the factors that can
impact member
         retention to address the decrease in membership in New Jersey, New
York and Ohio from
         2019 to 2020.
Note 8: Benefits Payable, page F-21

5.       We note your response to prior comment 21. Please address the
following:
             As previously requested, Revise your accounting and related
disclosures to include
            CAE with your claims incurred, net on the face of your statement of
operations as
            required by Rule 7-04.5 of Regulation S-X.
             Revise your accounting and related disclosures to include your
liability for CAE with
            your benefits payable on your balance sheet as required by Rule
7-03(a)13(a) of
            Regulation S-X.
             To the extent that you believe the guidance referenced in the
preceding bullets is not
            required, tell us why in your response and reference for us the
authoritative literature
            you rely upon to support your accounting.
6.       We note your response to prior comment 22 and that $516.1 million of
reinsurance
         recoverables were collected in the first quarter of 2020 and that such
amounts related to
         quarters three and four of 2019. We also note on page F-18, that you
disclose reinsurance
         losses ceded for the entire year ended December 31, 2019 were $516.1
million. Please
         explain this discrepancy and revise your disclosures accordingly.
 Mario Schlosser
Mulberry Health Inc.
December 30, 2020
Page 3

       You may contact Michelle Miller at 202-551-3368 or Mark Brunhofer at
202-551-3638 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Tonya K. Aldave at 202-551-3601 or John Dana Brown at 202-551-3859 with
any other
questions.



FirstName LastNameMario Schlosser                        Sincerely,
Comapany NameMulberry Health Inc.
                                                         Division of
Corporation Finance
December 30, 2020 Page 3                                 Office of Finance
FirstName LastName