November 22, 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
           Response Dated October 25, 2024
           File No. 001-39785
Dear Marc Benathen:

        We have reviewed your October 25, 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 October
16, 2024 letter.

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

1.     In response to comment 3 you reference obsolete inventory that you
destroyed. Please
       provide us the following information so that we are able to further
understand the
       basis for your determination that the adjustments are one-time,
non-recurring charges,
       for 2022, 2023 and 2024:

             the name of each brand;
             the amount recorded as obsolete inventory;
             the quarterly period and year the amount was recorded as obsolete
inventory;
             the reason the brand was sunset;
             the reason the inventory was destroyed, and not otherwise sold;
and
 November 22, 2024
Page 2

             the amount of any lower of cost or market adjustments recorded
during 2022,
           2023 and 2024 that did not relate to sunset brands. Provide us the
related facts and
           circumstances.
2.    In addition, you reference one-time accounts receivable and sales return
adjustments.
      Please provide us the following information so that we are able to
further understand
      the basis for your conclusion:

             the amount of each separate adjustment;
             the period and year the adjustment was recorded; and
             a description of the facts and circumstances related to each
adjustment.
3.    In addition, you reference that litigation costs include one-time
non-recurring
      expenses for matters that are extraordinary in nature and scope and that
should not be
      classified as normal operating expenses. Please provide us the following
information
      so that we are able to further understand the basis for your conclusions:
the amount
      recorded for each separate matter, by year and by type of cost incurred
(e.g., external
      attorneys fees, internal costs, amounts recorded pursuant to settlement
agreements,
      etc.).
4.    In addition, please describe for us in further detail your insurance
acceptance
      readiness expenses (including how they relate to your operations, revenue
generating
      activities, and business strategy), why you incurred these expenses in
2022, 2023 and
      2024, and when these costs will no longer be incurred, as appears to be
indicated in
      your response.
5.    We note your response to comment 4. In future filings, please reconcile
Telehealth
      Adjusted EBITDA from Telehealth operating loss as presented in the
segment data
      footnote as the most directly comparable financial measure calculated and
presented
      in accordance with GAAP. Provide us with a draft of your revised
disclosure as part
      of your response.
6.    We note preferred stock dividends for 2023 and 2022 were $3,106,250 each
fiscal
      year, as presented in the statements of operations, and the non-GAAP
adjustments for
      dividends were $5,371,450 and $3,250,250, for 2023 and 2022. Please
clarify for us
      the reason for the differences between the amounts, for each year
presented. Please
      similarly address the difference in dividends amounts as it relates to
your 2024 and
      2023 interim financial statements and the related non-GAAP adjustments.
       Please contact Christie Wong at 202-551-3684 or Michael Fay at
202-551-3812 if you
have questions regarding comments on the financial statements and related
matters.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Industrial Applications and
                                                            Services