August 29, 2024

Tim Canning
Chief Executive Officer
Danam Health, Inc
3000 Bayport Drive
Suite 950
Tampa, FL 33607

       Re: Danam Health, Inc
           Amendment No. 1 to Registration Statement on Form S-1
           Filed August 2, 2024
           File No. 333-280945
Dear Tim Canning:

       We have reviewed your registration statement and have the following
comment(s).

       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.

Amendment No. 1 to Registration Statement on Form S-1 filed August 2, 2024
Risk Factors
Changes in economic conditions could adversely affect consumer/client buying
practices . . .,
page 13

1.     We note your disclosure that "[i]n addition to general levels of
inflation, Danam will also
       be subject to risk of specific inflationary pressures on product
prices." To the extent
       applicable, please revise your summary risk factors, include a
standalone risk factor to
       disclose how recent inflationary pressures have materially impacted your
business and
       operations. For example, identify the types of inflationary pressures
you are facing and
       how your business has been affected. Lastly, please make conforming
revisions in your
       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       section.
 August 29, 2024
Page 2
Risks Related to Financial and Accounting Matters
Danam and its subsidiaries have, and entities that Danam may acquire could
have, significant
outstanding debt . . ., page 25

2.     Please disclose here the dollar amount of the outstanding debt and
credit obligations of
       Danam and its subsidiaries.
Danam's level of debt may negatively impact its liquidity . . ., page 27

3.     We note your disclosure that "Danam   s bank debt contains a variable
interest rate
       component based on its corporate credit ratings." To the extent
material, please revise
       your summary risk factors and risk factors sections to specifically
identify this risk. In
       your risk factor disclosure, please discuss the impact of any rate
increases on your
       operations and how your business has been affected. For example,
describe whether your
       borrowing costs have recently increased or are expected to increase and
your ability to
       pass along your increased costs to your customers.
The market price of Danam Common Stock may decline as a result of various
market factors.,
page 38

4.     We note your representation that "[i]f an active market for Danam   s
securities develops
       and continues, the trading price of Danam   s securities could be
volatile and subject to
       wide fluctuations in response to various factors, some of which will be
beyond Danam   s
       control." We also note instances of extreme stock price run-ups followed
by rapid price
       declines and stock price volatility seemingly unrelated to company
performance following
       a number of recent initial public offerings, particularly among
companies with relatively
       smaller public floats. Please revise this risk factor to clearly state
that such volatility,
       including any stock-run up, may be unrelated to your actual or expected
operating
       performance and financial condition or prospects, making it difficult
for prospective
       investors to assess the rapidly changing value of your stock.
Capitalization, page 44

5.     Please revise to include amounts due to related parties and due to
seller in your total pro
       forma capitalization.
Unaudited Pro Forma Combined Financial Information, page 47

6.     Please provide a pro forma combined statement of operations for only the
most recent
       fiscal year and for the period from the most recent fiscal year end to
the most recent
       interim date for which a balance sheet is required. Refer to Rule
11-02(c)(2)(i) of
       Regulation S-X.
7.     Please tell us your consideration of presenting the acquisitions of Wood
Sage LLC and
       Wellgistics LLC in the pro forma balance sheet as of the interim pro
forma balance sheet
       date since the acquisition dates are subsequent to your latest interim
pro forma balance
       sheet date presented. Refer to Rule 11-02(a)(6)(i)(A) of Regulation S-X.
This comment
       also applies to adjustment (c) on page 49.
8.     Please present the transactions in your pro forma interim statement of
operations and pro
       forma statement of operations for the year ended December 31, 2023 as if
they occurred
       on January 1, 2023. Refer to Rule 11-02(a)(6)(i)(B) of Regulation S-X.
 August 29, 2024
Page 3

Unaudited Pro Forma Combined Statement of Operations, page 47

9.     Please revise to present pro forma basic and diluted per share amounts
in your interim and
       year end pro forma combined statement of operations. Refer to Rule
11-02(a)(9) of
       Regulation S-X.
10.    Please tell us if you plan to continue to pay the management service fee
to Normad
       Capital disclosed on pages F-66 and F-82 subsequent to your acquisition
and your
       consideration of making pro forma adjustments in your pro forma combined
statements of
       operations for the period and year presented.
Wellgistics Membership Interest Purchase Agreement, page 50

11.    Please describe in detail the changes to the purchase payment that the
parties are
       negotiating. In doing so, please describe which of the payment terms are
being negotiated,
       as well as any other material provisions that are being renegotiated.
Please clarify why the
       parties are renegotiating the terms now, and explain how the
renegotiation process
       commenced, including who initiated it. Further, please clarify whether,
as a result of the
       renegotiation process, you still expect the transaction to close in the
third quarter of 2024.
       Please clarify whether any of the proceeds from this offering could be
used to satisfy
       payment obligations related to the transaction and revise your
disclosure accordingly.
       Finally, please tell us whether there is now an increased risk that the
transaction might not
       close on time or at all, and revise your disclosure, including your risk
factor disclosure,
       accordingly.
Management's Discussion and Analysis of Financial Condition and Results of
Operations of
Wood Sage
Key Components of Results of Operations
Revenues, page 57

12.    With a view to providing investors with a complete and balanced picture
of Wood
       Sage's business and revenues, please disclose here a breakdown of
revenue for each of
       CSP's major services. In this regard, we note your disclosure on pages
69-70 that CSP   s
       general and specialty pharmacy services include (i) patient care
coordination, (ii) clinical
       services, (iii) compliance and persistency programs, (iv) patient
financial assistance, (v)
       prior authorization and (vi) risk evaluation and mitigation strategy;
however, it is not clear
       how much of these services contributes to CSP's revenue.
Business, page 68

13.    We note the risk factor on page 25 that "Danam   s quarterly results may
fluctuate
       significantly based on seasonality and other factors." Please revise
here to include a
       discussion of the manner in which seasonality affects your business.
Refer to Item
       101(c)(1)(v) of Regulation S-K.
Pharmacies, page 75

14.    We note your representation that DelivMeds    digital pharmacy concept
provides the
       enumerated benefits. Please provide your basis for the stated benefits,
or revise to
       characterize them as management's belief.
 August 29, 2024
Page 4

Information Technology, page 79

15.    This section contains lengthy, technical information. For example, you
discuss Dart and
       Flutter, Angular and TypeScript as well as their roles in your core
engine. Please define
       any technical jargon and revise in a way that a lay person can
understand the role of your
       information technology in the DelivMeds platform.
Certain Relationships and Related Person Transactions, page 93

16.    Please clarify whether the disclosure in this section includes related
party transactions
       since the beginning of your last fiscal year, and revise as appropriate.
In this regard, we
       note your disclosure that "the following is a description of each
transaction since January
       1, 2024 (emphasis added)." Refer to Item 404 of Regulation S-K.
TRxADE Promissory Note, page 93

17.    Please revise to provide all of the information required by Item
404(a)(5) of Regulation S-
       K with respect to this related party loan. For example, we note that the
interest rate is not
       provided for the promissory note. Additionally, please file any related
agreements as
       exhibits to the registration statement.
Executive Employment Agreements, page 94

18.    We note that you have entered into a contract agreement Aletheia
Strategic Advisory LLC
       pursuant to which Vishnu Balu has agreed to serve as Danam's Chief
Financial
       Officer. Please file this employment agreement as an exhibit to the
registration statement
       or tell us why you believe you are not required to do so. Refer to Item
601(b)(10)(ii) of
       Regulation S-K.
Danam Health, Inc.
Consolidated Financial Statements
Report of Independent Registered Public Accounting Firm, page F-2

19.    We note the operations of Danam Health Inc., Wellgistics LLC., and Wood
Sage
       LLC, appear to be primarily located in Florida, but your audit reports
were signed by an
       audit firm based in Chennai, India. After asking your auditor, please
tell us where the
       majority of the audit work was conducted and how they concluded it is
appropriate to
       have an audit report issued by an auditor licensed in India. In your
response, please tell us
       whether another audit firm assisted in the audit. If so, please tell us
the name of the other
       firm, whether the other firm is registered with the PCAOB, and the
extent to which audit
       work was performed by the other firm.
20.    Please have your auditor revise their report to address the following:
           Revise the first paragraph to provide an opinion for each period
included in the audited
       financial statements.
           The period your auditors were appointed is not a component of the
"Opinion on the
       Financial Statements" section, refer to paragraph .08 of AS 3101.
           Have your auditor retitle the section titled "Responsibilities of
the Management for the
       Financial Statement" to "Basis for Opinion." Refer to paragraph .09 of
AS 3101.
           The statement that "management is required to evaluate whether there
are conditions or
       events, considered in the aggregate, that raise substantial doubt about
Danam Health Inc   s
 August 29, 2024
Page 5

       ability to continue as a going concern...," is not a component of the
auditor report. Refer
       to paragraph .18(a) of AS 3101 in regard to the auditors' responsibility
as it relates to
       going concern.
           Revise the auditors' statement on independence to reflect their
"requirement to be
       independent with respect to the company in accordance with the U.S.
federal securities
       laws and the applicable rules and regulations of the SEC and the PCAOB."
Refer to
       paragraph .09(g) of AS 3101.
Statement of Operations, page F-4

21.    Please present net loss per share. Refer to FASB ASC 260-10-50.
22.    We note the financial statements were presented for the year ended for
December 31,
       2022 yet Danam was incorporated on September 6, 2022, Please revise to
state these
       statements cover the date of inception, September 6, 2022 to December
31, 2022. Please
       make similar changes to the statements of cash flows.
Note 1. Organization and Summary of Significant Accounting Policies
Basis of Presentation, page F-7

23.    Please revise to clarify that your financial statements do not include
amounts related to the
       acquisition of Wood Sage, LLC which closed in June 2024.
WOOD SAGE, LLC Annual Financial Statements
Report of Independent Registered Public Accounting Firm, page F-22

24.    Please have your auditor revise their report to address the following:
           Revise the first paragraph to provide an opinion for each period
included in the audited
       financials statements.
           The period your auditors were appointed is not a component of the
"Opinion on the
       Financial Statements" section, refer to paragraph .08 of AS 3101.
           Have your auditor retitle the section titled "Responsibilities of
the Management for the
       Financial Statement" to "Basis for Opinion." Refer to paragraph .09 of
AS 3101.
           The statement that "management is required to evaluate whether there
are conditions or
       events, considered in the aggregate, that raise substantial doubt about
Wood Sage LLC   s
       ability to continue as a going concern...," is not a component of the
auditor report. Refer
       to paragraph .18(a) of AS 3101 in regards to the auditors responsibility
as it relates to
       going concern.
           Revise the auditors statement on independence to reflect their
"requirement to be
       independent with respect to the company in accordance with the U.S.
federal securities
       laws and the applicable rules and regulations of the SEC and the PCAOB."
Refer to
       paragraph .09(g) of AS 3101.
Note 3. Business Combinations, page F-32

25.    Please tell us your consideration of providing the financial statements
under Rule 8-04 of
       Regulation S-X related to your acquisitions of Alliance Pharma Solutions
LLC
       and Community Specialty Pharmacy, LLC.
 August 29, 2024
Page 6
Wellgistics, LLC Annual Financial Statements
Report of Independent Registered Public Accounting Firm, page F-50

26.    Please have your auditor revise their report to address the following:
           Revise the first paragraph to provide an opinion for each period
included in the audited
       financial statements.
           The period your auditors were appointed is not a component of the
"Opinion on the
       Financial Statements" section, refer to paragraph .08 of AS 3101.
           Have your auditor retitle the section titled "Responsibilities of
the Management for the
       Financial Statement" to "Basis for Opinion." Refer to paragraph .09 of
AS 3101.
           The statement that "management is required to evaluate whether there
are conditions or
       events, considered in the aggregate, that raise substantial doubt about
Wellgistics LLC   s
       ability to continue as a going concern...," is not a component of the
auditor report. Refer
       to paragraph .18(a) of AS 3101 in regards to the auditors responsibility
as it relates to
       going concern.
           Revise the auditors statement on independence to reflect their
"requirement to be
       independent with respect to the company in accordance with the U.S.
federal securities
       laws and the applicable rules and regulations of the SEC and the PCAOB."
Refer to
       paragraph .09(g) of AS 3101.
General, page F-55

27.    Please tell us your consideration of providing the financial statements
under Rule 8-04 of
       Regulation S-X related to your acquisition of American Pharmaceutical
Ingredients, LLC
       and providing the disclosures in FASB ASC 805-10-50.
Wellgistics, LLC Interim Financial Statements
Note 1 Organization and Summary of Significant Accounting Policies
Unaudited Interim Financial Information, page F-74

28.    Please clarify your disclosure of filing Form S-4 on May 2, 2024 here
and elsewhere in
       this filing, or revise accordingly.
General

29.    Please provide us with supplemental copies of all written
communications, as defined in
       Rule 405 under the Securities Act, that you, or anyone authorized to do
so on your behalf,
       have presented or expect to present to potential investors in reliance
on Section 5(d) of the
       Securities Act, whether or not you retained, or intend to retain, copies
of those
       communications. Please contact the staff member associated with the
review of this filing
       to discuss how to submit the materials, if any, to us for our review.

        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
 August 29, 2024
Page 7

       Please contact Tony Watson at 202-551-3318 or Lyn Shenk at 202-551-3380
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Rucha Pandit at 202-551-6022 or Dietrich King at 202-551-8071 with any other
questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Trade &
Services
cc:   Kate Bechen