August 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
           Form 10-Q for Fiscal Quarter Ended June 30, 2024
           Filed August 14, 2024
           Response Letter Dated August 7, 2024
           File No. 000-49709
Dear Matthew Shafer:

       We have reviewed your August 7, 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
30, 2024 letter.

Form 10-Q for Fiscal Quarter Ended June 30, 2024
1. Summary of Significant Accounting Polices
Accounts Receivable, page 9

1.     We note that during the first quarter of fiscal year 2024 you recognized
$0 credit loss
       expense for the accounts receivable recognized during the period.
However, your
       accounting policy indicates that you use the loss rate method to
recognize an allowance
       for credit losses to present the net amount expected to be collected for
trade receivables.
       Based on your accounting policy and the guidance in ASC 326-20-30-1
through 30-10, it
       is unclear how you concluded that the associated credit loss risk was
zero. Please advise.
       To the extent that you did not recognize a credit loss expense for the
accounts receivable
       recognized during the second quarter of fiscal year 2024, please explain
the
 August 16, 2024
Page 2

       appropriateness of your accounting.
2.     Please disclose the carrying value of the accounts receivable factored
(sold) during the
       six-months ended June 30, 2023 along with the corresponding amount of
cash received
       from the third party(s). Refer to comments 1 and 3 along with the
guidance in ASC 326-
       20-50- 11.i.
3.     We note your disclosure on page 10 that the $1,242,017 of credit loss
expense recognized
       during the six months ended June 30, 2024 is not material in relation to
the accounts
       receivable balances and revenue. Please revise this statement to clarify
that the expense is
       material, as it is 25% of your revenue and is substantially in excess of
income from
       continuing operations and net loss.
Item 2. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Liquidity and Capital Resources, page 46

4.     We note your disclosure on page 48 that the average collection time for
accounts
       receivable is approximately 470 days from the patient   s initial date
of service, which is
       the same disclosure provided in your fiscal year 2023 Form 10-K for
fiscal year 2023.
       However, on page 9, you state,    [c]ollection of that revenue typically
occurs eighteen to
       twenty-four months later and after the patient claim develops and
settles.    We further note
       your statements on pages 10, 44, 46 and 47 that you have    experienced
lower than normal
       settlements [of your] accounts receivable   . Please revise your
disclosures to address these
       apparent inconsistencies.
5.     We note your response to the fourth bullet of comment 2 and to comment
5. We further
       note that for the six-months ended June 30, 2024, you have recognized
total expense of
       $1,242,017 to the allowance for credit loss and wrote-off $1,199,155
from the allowance.
       Please expand your disclosures to provide a comprehensive discussion and
analysis of the
       credit loss expense recognized for the current period, any adjustments
to previously
       recognized credit loss expense, and the write-offs of the accounts
receivable-net deemed
       uncollectible to provide investors with sufficient information to
understand the specific
       facts and circumstances impacting the recoverability of accounts
receivable-net. This
       disclosure should include quantification of the components of the
$1,242,017 expense.
       To the extent that a portion of the expense relates to you accepting a
reduced amount to
       settle outstanding accounts receivable-net, please disclose the
specifics about each of
       these fact patterns, the carrying amount of the accounts receivable-net
and the settlement
       amount received, and how such settlements are possible given your
statement that you do
       not receive payment until the patient receives a settlement.
6.     We note your statements on pages 44 and 46 that your repayment of the
liability
       associated with third-party factoring of accounts receivable from
previous years is
       impacting the increase in bad debt expense and you are experiencing
lower than normal
       settlements of your accounts receivable. In response to the third bullet
of comment 1 in
       our letter dated July 16, 2024, you revised your disclosures on page 46
of Amendment
       No. 3 to Form 10-K for fiscal year ended December 31, 2023, to state
that the accrued
       liability for collections of previously factored receivables represents
the collections (i.e.,
       cash received) for the receivables sold to third party factors where the
collections received
       are then remitted to the third party factors. Given the nature of this
liability, and the fact
       that your previously factored receivables are no longer reflected on
your balance sheet, it
 August 16, 2024
Page 3

       is not clear how the repayment of this liability would impact the
collectability of your
       accounts receivable balances as of each period presented. As such,
please remove
       reference to the settlement of this liability from your discussion of
the collectability of
       your accounts receivable-net balance and the associated allowance for
credit loss expense.
       Also, please remove the reference in the analysis provided for selling,
general and
       administrative expenses for both periods presented.
       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