July 26, 2024

Julia Qian
Chief Financial Officer
Health In Tech, Inc.
701 S. Colorado Ave, Suite 1
Stuart, FL 34994

        Re: Health In Tech, Inc.
            Amendment 2 to Draft Registration Statement on Form S-1
            Submitted June 27, 2024
            File No. 377-07195
Dear Julia Qian:

     We have reviewed your amended draft registration statement and have the
following
comments.

        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 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 the information you provide in response to this letter
and your amended
draft registration statement or filed registration statement, we may have
additional
comments. Unless we note otherwise, any references to prior comments are to
comments in our
June 20, 2024 letter.

Amendment 2 to Draft Registration Statement on Form S-1
Prospectus Summary, page 1

1.     We note your response to comment 1. We also note that you did not revise
the charts on
       pages 2 and 3 where you state    Hi Card transforms the landscape...
Please provide the
       basis for this statement. Also, please file a consent related to the
report you commissioned
       from "Frost & Sullivan" and either provide the report supplementally or
file it as an
       exhibit.
2.     We note your response to prior comment 3 and revised disclosures on
pages 45 and 57. It
       is still unclear whether and how your typical contractual relationships
involve brokers,
       TPAs, small employers and carriers individually, as multi-party
agreements or otherwise.
       For example, are "business relationships" with licensed brokers, as
referenced on page 57,
 July 26, 2024
Page 2

       part of a contractual relationship involving small employers and/or
carriers? Where you
       state that small employers pay the fees under SMR and HI Card programs,
are such fees
       paid directly to you, through brokers or TPAs or otherwise? Please
provide a summary
       explaining the parties and terms of a typical contractual relationship.
Lock-Up, page 9

3.     Please indicate the purpose of the stock split referenced in the fourth
bullet point.
Our customers sensitive, proprietary, or confidential information could be
leaked..., page 23

4.     We note that the revised risk factor contains additional discussion of
mitigating factors
       and multiple risks related to the use of AI technology. Please relocate
mitigating
       statements to Business or where appropriate along with a more robust
discussion of your
       use of AI, and revise the risk factor to provide separate subheadings
above each particular
       risk. Additionally, we note the statement that you provide "bindable
quotes solely using
       [y]our AI-backed eDIYBS platform...unless the eDIYBS platform raises
certain unknown
       risk flags that require further manual review." To provide context,
please quantify the
       approximate percentage of services where bindable quotes are provided
solely using AI
       without further manual review.
5.     Please revise Business or where appropriate to clarify the principal
areas where you use
       artificial intelligence, and if material summarize the related
regulations covering your
       use(s) of AI and the extent to which you monitor and assess your use(s)
of AI. For
       example, it is unclear if your use of third-party AI information in the
eDIYBS platform is
       the only way you use artificial intelligence and whether you evaluate
and assess the third-
       party AI information used in the eDIYBS platform with respect to
accuracy and
       compliance and/or conduct periodic audits of the information or
otherwise monitor its use.
       Please confirm that you have disclosed the material terms of the
agreement with the third-
       party provider of AI information and either file the agreement or advise
us why you
       believe it should not be filed as a material agreement under Item
601(b)(10).
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
43

6.     Please refer to prior comment 5. It does not appear that any revisions
made in your
       amendment addressed the issues in prior comment 5, thus we are reissuing
the comment.
       Please revise your Management   s Discussion and Analysis of Financial
Condition and
       Results of Operations section to discuss your financial condition and
changes in financial
       condition for each of the periods presented as required by Item 303 of
Regulation S-K.
       For example, please discuss the material changes in your accounts
receivable, other
       receivables, software, notes payable, and accounts payable and accrued
expenses.
Note to the Consolidated Financial Statements, page F-7

7.     Please refer to prior comment 19. We note that ASC 275-10-50-16
addresses
       vulnerabilities related to a variety of concentrations. Please tell us
in detail if you are
       vulnerable to any type of concentration detailed in this guidance and
revise your
       disclosure as needed.
 July 26, 2024
Page 3

Other Receivables, page F-10

8.     Please refer to prior comment 16. Please tell us in detail and revise
disclosure as needed to
       address the following:

             Detail the name of the party you transferred $1,650,000 to (e.g.
an insurance carrier,
           small employer, etc.).
             Detail all of the contractual rights you obtained and clarify
which party is
           contractually obligated to pay you, the timing of the payments, how
the amounts of
           payments are determined and if the payments are contingent on any
events.
             Based on information in your response dated May 28, 2024 and your
disclosure on
           page F-10, it appears you purchased the rights, title, interest, and
collection rights of
           receivables or related to fees. Please explain the background facts
and circumstances
           related to the receivables or fees, how the party was related to
these receivables/fees
           and why they had collection rights.
             Clarify how the collection rights relate to the information in the
response that appears
           to state that the carrier only gets cash flows if there is cash
remaining in the claim
           fund at the end of the run-out period and the small employer decides
to give these
           funds to the carrier in exchange for a discount in future premiums.
             Clarify the key risks relating to the collection of the cash flows
including
           circumstances in which you would collect substantially less than or
greater than your
           investment.
Revenue Recognition, page F-11

9.     We note your revised disclosure on page F-12 that SMR along with HI Card
have
       contractual relationships with TPAs. Considering that you have
identified the small
       employers as your customers, it appears that TPAs may not be customers
under ASC 606.
       If so, please clarify this and explain how the contractual relationship
with non-customers
       impacts your revenue recognition policies. Alternatively, disclose this
relevant
       information outside of your revenue recognition policy disclosure.
Program and platform management services, page F-13

10.    Please revise your program and platform management services revenue
recognition policy
       to more clearly identify the promised services provided to small
employers in the
       contracts. Also, disclose when those performance obligations are
satisfied and identify the
       contractual obligations that are performed over the term of the
contract.
 July 26, 2024
Page 4

       Please contact William Schroeder at 202-551-3294 or Michael Volley at
202-551-3437 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Todd Schiffman at 202-551-3491 or James Lopez at 202-551-3536 with any
other
questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Finance