July 22, 2024

Zvi Glasman
Chief Financial Officer
PetIQ, Inc.
230 E. Riverside Drive
Eagle, Idaho 83616

        Re: PetIQ, Inc.
            Form 10-K for Fiscal Year Ended December 31, 2023
            File No. 001-38163
Dear Zvi Glasman:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2023
Item 7 - Management's Discussion and Analysis of Financial Condition and
Results of Operations
Results of Operations
Year Ended December 31, 2023 Compared With Year Ended December 31, 2022, page
36

1.     Please consider providing a more robust disclosure regarding the
underlying reasons for
       your material revenue increase. For example, regarding products discuss
further what you
       mean by broad strength and growth, and any associated underlying factors
and trends. For
       services, discuss the operational improvements cited that contributed to
increased
       revenues and why/how. Also for services, discuss the extent that cited
increases in clinic
       counts, average dollar per clinic and average dollar per pet served
contributed to the
       increase. Refer to Item 303(a), introductory paragraph of (b) and
(b)(2)(ii) and (iii) of
       Regulation S-K and Section III.B.4 of Release No. 33-8350 for guidance.
2.     Since cost of revenues is material to your results, please consider a
separate quantitative
       and qualitative comparable analysis of it to the extent material in
helping investors better
       understand your operations and results. Refer to Item 303(b). In doing
so, consider
       discussing the impact of each component of cost of revenues that caused
cost of revenues
 July 22, 2024
Page 2

       to materially vary (or not vary when expected to). Consider performing
the analysis at the
       segment level to the extent meaningful in further understanding your
operations and
       results.
Consolidated Non-GAAP Financial Measures, page 38

3.     You include an adjustment for impairment and other asset charges to
arrive at your non-
       GAAP financial measure "EBITDA." As your current calculation does not
comply with
       EBITDA as defined in Exchange Act Release No. 47226, please revise to
exclude the
       impairment and other asset charges adjustment from your calculation of
EBITDA or
       rename the measure. Refer to Question 103.01 of the Compliance and
Disclosure
       Interpretations on Non-GAAP Financial Measures.
Financial Condition, Liquidity, and Capital Resources
Cash Flows
Cash Provided by Operating Activities, page 40

4.     You disclose the increase in cash provided by operating activities was
primarily
       attributable to the increase in profitability and changes in non-cash
items. Please expand
       your analysis to disclose the material underlying factors that impact
the comparability
       between periods of reported operating cash flows in terms of cash.
Quantify each factor
       cited so investors may understand the magnitude of each. Your discussion
should focus on
       factors that directly affect cash, and not merely refer to
results/profitability since it is
       recorded on an accrual basis or noncash items that do not affect cash.
Refer to the
       introductory paragraph of Section IV.B. and all of B.1 of Release No.
33-8350 for
       guidance.
       In closing, 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.

       Please contact Stephen Kim at 202-551-3291 or Doug Jones at 202-551-3309
with any
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Trade &
Services