October 28, 2024

Ted Kellner
Nominating Shareholder
AIM ImmunoTech Inc.
790 North Water Street, Suite 2175
Milwaukee, WI 53202

       Re: AIM ImmunoTech Inc.
           PREC14A filed October 18, 2024
           Filed by Ted D. Kellner, Todd Deutsch, Robert L. Chioini, Paul W.
Sweeney
           File No. 1-27072
Dear Ted Kellner:

       We have reviewed your filing 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 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.

PREC14A filed October 18, 2024
Background to the Solicitation, page 5

1.     On page 9, we note your disclosure that the appeal proceeding in the
Florida federal
       court case is "pending." Please revise to provide additional information
as relevant.
       For example, we note that the docket reflects, among other things, that
the Appellant
       has filed its brief on September 4, 2024, and the Appellees' brief is
due November 4,
       2024.
Entrenchment Efforts and Lack of Accountability to Stockholders, page 13

2.     In several places in the proxy statement, including the first paragraph
on page 14, you
       present past voting percentages for the Company's directors as a
percentage of shares
       "eligible to vote." Here and throughout the proxy statement, clarify
whether you mean
       as a percentage of total shares outstanding or as a percentage of shares
voting at the
       relevant meeting, once a quorum is achieved. Make the same revisions
regarding
 October 28, 2024
Page 2

       similar disclosure about say-on-pay voting throughout the proxy
statement.
Proposal 1. Election of Directors, page 19

3.     We note the disclosure about Mr. Deutsch's work with Aramas Capital
beginning in
       2024. Please provide the information about the principal business of
Aramas Capital
       required by Item 7(b) of Schedule 14A and Item 401(e)(1) of Regulation
S-K.
4.     In this section, state how you will treat proxies voted for more than
four director
       nominees and fewer than four director nominees. We note the following
disclosure in
       the proxy card: "Vote 'FOR' only up to four nominees in total. You may
vote
       'FOR' less than four nominees, but if you vote 'FOR' more than four
nominees, your
       votes on Proposal 1 will be considered invalid and will not be counted."
Vote Required For Approval, page 25

5.     The only voting options for Proposal 1 are "FOR" and "WITHHOLD."
Therefore,
       please revise the reference to "abstentions" and their effect on the
vote on Proposal 1
       found on page 25.
6.     Refer to the disclosure in the first paragraph on page 26. Revise to
state that the
       Kellner Group may use discretion only on matters not known to them
within a
       reasonable time before the solicitation will be presented at the annual
meeting. See
       Rule 14a-4(c)(3).
Solicitation of Proxies, page 27

7.     Quantify the total amount of the expenses for which the Kellner Group or
affiliated
       entities are seeking reimbursement from the Company, in particular as to
expenses
       already incurred for prior solicitations and litigation expenses.
Incorporation by Reference, page 33

8.     Revise to specifically identify the information incorporated by
reference from the
       Company's proxy statement by revising the vague references to "among
other things,"
       and "other important information." See Rule 14a-5(c).
Schedule I, page 34

9.     No information is provided as to Mr. Sweeny in the Schedule, although
disclosure on
       page 28 indicates he owns 2,000 shares of Common Stock of the Company.
Please
       confirm Mr. Sweeney's shares were purchased more than two years ago, or
revise
       Schedule I to provide information as to his purchases (and sales if
applicable). See
       Item 5(b)(1)(vi) of Schedule 14A.
        We remind you that the filing persons are responsible for the accuracy
and adequacy
of their disclosures, notwithstanding any review, comments, action or absence
of action by
the staff.

      Please direct any questions to Eddie Kim at 202-679-6943 or Christina
Chalk at 202-
551-3263.
 October 28, 2024
Page 3



                   Sincerely,

                   Division of Corporation Finance
                   Office of Mergers & Acquisitions