October 16, 2024

Marc Benathen
Chief Financial Officer
LifeMD, Inc.
236 Fifth Avenue, Suite 400
New York, New York 10001

       Re: LifeMD, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2023
           File No. 001-39785
Dear Marc Benathen:

       We have limited our review of your filing to the financial statements
and related
disclosures 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.

Press Releases Dated March 11, 2024 and August 7, 2024
Reconciliation of GAAP Net Loss to Adjusted EBITDA to Cash Adjusted EBITDA,
page 1

1.     We note you present Cash Adjusted EBITDA, which includes an adjustment
for the
       change in deferred revenue and is reconciled from Adjusted EBITDA.
Please explain
       to us how Cash Adjusted EBITDA is useful to an investor given that it
appears to
       combine accrual and cash accounting concepts. In addition, please
explain to us how
       you considered the Division of Corporation Finance Non-GAAP Financial
Measures
       C&DI 100.04 as it relates to your adjustment for the change in deferred
revenue.
2.     Please explain to us your methodology for determining your deferred
revenue
       adjustment for fiscal year 2022 and 2023, and describe to us any changes
to your
       methodology for fiscal year 2024.
 October 16, 2024
Page 2



3.     We note you make non-GAAP adjustments for litigation costs, inventory
and reserve
       adjustments, and insurance acceptance readiness. Please describe to us
in greater
       detail the nature of the underlying costs for 2022, 2023, and 2024 for
each of these
       types of costs. As part of your response, describe the related facts and
circumstance
       regarding the costs being incurred. In addition, please explain to us
how you
       considered the Division of Corporation Finance Non-GAAP Financial
Measures
       C&DI 100.01 as it relates to these non-GAAP adjustments.
Reconciliation of Telehealth GAAP Net Loss to Telehealth Adjusted EBITDA, page
2

4.     We note you present Telehealth Adjusted EBITDA and reconcile this amount
to
       Telehealth net loss attributable to common shareholders. Please tell us
how your
       reconciliation complies with Rule 100(a) of Regulation G. Specifically,
address how
       you evaluated whether Telehealth net loss attributable to common
shareholders is
       a financial measure calculated and presented in accordance with
Generally Accepted
       Accounting Principles and clarify why you do not reconcile to Telehealth
operating
       loss as set forth in the segment data footnote of your financial
statements.
        In closing, 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.

       Please contact Christie Wong at 202-551-3684 or Michael Fay at
202-551-3812 with
any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Industrial
Applications and
                                                           Services