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                           June 14, 2023

       Kevin Wirges
       Chief Financial Officer and Treasurer
       CareMax, Inc.
       1000 NW 57th Court, Suite 400
       Miami, Florida 33126

                                                        Re: CareMax, Inc.
                                                            Form 10-K for the
Year Ended December 31, 2022
                                                            Form 10-K/A for the
Year Ended December 31, 2021
                                                            Correspondence
Letter dated May 15, 2023
                                                            File No. 1-39391

       Dear Kevin Wirges:

              We have reviewed your May 15, 2023 response to our comment letter
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. Unless we note otherwise, our references to prior comments are
to comments in our
       April 20, 2023 letter.

       Form 10-K for the Year Ended December 31, 2022

       Adjusted EBITDA, page 69

   1.                                                   We note your response
to comment 1. In regard to compensation expenses of $4,425,000,
                                                        which are being
adjusted for in your determination of Adjusted EBITDA, please address
                                                        the following:
                                                            Please quantify the
amounts associated with stay-on bonuses, severance, and
                                                             duplicate
employees separately;
                                                            Discuss how you
determined that the expenses excluded are incremental costs and
                                                             not normal,
recurring cash operating expenses necessary to operate your business;
                                                            With specific
reference to each compensation category (e.g. stay-on bonuses,
                                                             severance and
duplicate employees costs), please more fully explain how the removal
 Kevin Wirges
CareMax, Inc.
June 14, 2023
Page 2
              of these costs are consistent with Question 100.01 of the
Non-GAAP Financial
              Measures Compliance & Disclosure Interpretations, as updated
December 13, 2022.
              In this regard, we note that these costs appear related to
revenue generation;
                With regards to stay-on bonuses, please tell us the typical
length of time the bonuses
              commit the employees to stay with the company; and
                Specifically tell us the periods over which these types of
compensation costs are
              expected to be incurred. For any costs that extend beyond a year,
please further
              explain how you determined that the adjustment for these costs is
appropriate. Refer
              to Question 100.01 of the Non-GAAP Financial Measures Compliance
& Disclosure
              Interpretations, as updated December 13, 2022.
2.       We note your response to comment 3. Please clarify your disclosures in
a similar manner
         to your response.
       You may contact Nudrat Salik at (202) 551-3692 or Jeanne Baker at (202)
551-3691 if
you have any questions.



                                                               Sincerely,
FirstName LastNameKevin Wirges
                                                               Division of
Corporation Finance
Comapany NameCareMax, Inc.
                                                               Office of
Industrial Applications and
June 14, 2023 Page 2                                           Services
FirstName LastName