July 16, 2024

Matthew Shafer
Chief Financial Officer
Cardiff Lexington Corp
3753 Howard Hughes Parkway, Suite 200
Las Vegas, NV 89169

       Re: Cardiff Lexington Corp
           Form 10-K for Fiscal Year Ended December 31, 2023
           Filed March 27, 2024
           Response Letter Dated July 12, 2024
           File No. 000-49709
Dear Matthew Shafer:

       We have reviewed your July 12, 2024 response to our comment letter 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. Unless we
note otherwise, any references to prior comments are to comments in our July
10, 2024 letter.

Form 10-K for Fiscal Year Ended December 31, 2023
1. Summary of Significant Accounting Policies
Accounts Receivable, page F-9

1.     We note your response to prior comment 1. In addition to the expanded
disclosures
       requested in bullets 3, 5 and 6, please provide the following
disclosures to better address
       your business model and how that model impacts your operations,
including the
       collectability of your receivables.
           Provide a more comprehensive explanation of your healthcare services
and business
           model, including the general collection period for the services
provided. As part of
           your enhanced disclosures, specifically discuss what the Letter of
Protection is, the
           parties to the letter, how it ensures full payment of the services
provided, and what
           happens if a settlement is not reached and/or is for less than the
amount of revenue
           recognized for the services you provided.
 July 16, 2024
Page 2

             Provide risk factor disclosures that specifically addresses the
risks associated with
           your receivable lifecycle of 18 to 24 months. Address the current
lack of a process
           and the resources necessary to track the aging of your accounts
receivable and how
           this impacts your ability to accurately estimate that the receivable
lifecycle is 18 to 24
           months and that you have a 99% collection rate.
             Include a discussion in MD&A of your assessment that you have a
99% collection
           rate. In this regard, we note that you acquired Nova Ortho and Spine
LLC on May 31,
           2021, with the initial fair value of the acquired receivables at
$4.1 million as of
           December 31, 2021, which was reduced to $0.7 million once the
purchase price
           allocation was completed. We also note your history of factoring
these receivables at
           a 54% reduction of yield through April 2023. In addition, explain
the nature of the
           $1.2 accrued liability for collections of previously factored
receivable and why such
           accrual is necessary. Address whether this accrual impacts your
assessment of
           accounts receivable collectability.

2.     We note that the March 31, 2024 rollforward provided in your response
letter reports no
       provision recognized during the period. However, the cash flow statement
reports bad
       debt of $339,834. Please address this apparent inconsistency.
3.     Please tell us how you concluded that it is appropriate to classify all
of your accounts
       receivable-net balance as current given the estimated general collection
timeframe of 18
       to 24 months.
       Please contact Tracey Houser at 202-551-3736 or Jeanne Baker at
202-551-3691 if you
have questions regarding comments on the financial statements and related
matters.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Industrial Applications and
                                                             Services