May 21, 2025

Daniel Moorhead
Chief Financial Officer
ZYNEX INC
9655 Maroon Circle
Englewood, CO 80112

        Re: ZYNEX INC
            Form 10-K filed March 11, 2025
            File No. 001-38804
Dear Daniel Moorhead:

         We have reviewed your filing 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.

Form 10-K for Fiscal Year Ended December 31, 2024
We face periodic reviews and billing audits..., page 13

1.     We note your disclosure that you are subject to reviews and audits from
various
       parties; however, your risk factor does not indicate whether you have
historically
       experienced a corresponding material adverse effect on your business,
financial
       condition, results of operations, or cash flows. Also, the disclosure
does not indicate
       whether you have historically lost your right to participate in the
Medicare program,
       state programs, or one or more private payer networks. Please expand
your disclosure
       to clarify the extent to which you have experienced any material adverse
effects on
       your business or lost your right to participate in any government
programs or private
       payor networks, so that investors may better assess the magnitude of
these risks. In
       addition, please expand the succeeding risk factor about third-party
payer
       reimbursements to disclose the extent to which you have been materially
impacted.
       For example, we note your disclosure elsewhere that you were recently
notified that
       TriCare, one of your government payers, was temporarily suspending
payment as they
       review prior claims.
 May 21, 2025
Page 2

Critical Accounting Estimates, page 41

2.     Your risk factor on page 14 states that inaccurate accounting estimates
could have a
       material adverse impact on your operating results. Please expand your
critical
       accounting policy disclosures to include quantified information about
how changes to
       critical estimates underlying revenue recognition and collection of
receivables have
       impacted reported revenue and operating results. Refer to Item 303(b)(3)
of
       Regulation S-K


Form 10-Q filed April 29, 2025
Recent Events, page 7

3.     We note TriCare is suspending payments as they review prior claims.
Please discuss
       the nature of the TriCare matter including known material facts and
circumstances,
       such as the magnitude of claims potentially being reviewed by TriCare,
the potential
       impact to your financial statements if you have to reimburse TriCare,
and the
       underlying reasons for the dispute. Tell us your consideration of
providing disclosure
       responsive to ASC 450-20-50 in your footnotes.
Results of Operations
Net Revenue, page 22

4.     We note sales of devices and supplies during the quarter ending March
31, 2025,
       decreased 15% and 55% over the comparable interim period ending March
31, 2024,
       and 20% and 53% over the prior quarter ending December 31, 2024. Please
separately
       quantify the amount of the decrease from changes in volumes sold during
the periods,
       constrained revenue from fulfilling new orders related to current period
sales to
       TriCare patients, and adjustments to prior period revenue from changes
in estimates
       relating to the TriCare investigation.
5.     Please clarify how the TriCare matter impacted the accounting for 2025
first quarter
       sales where TriCare is a payer. Clarify whether revenue was recognized
on those sale
       transactions and, if so, whether there was a material change in the
estimated net sales
       prices.
Liquidity, page 23

6.     Please expand your disclosure to identify the expected sources of cash
that you intend
       to use in order to redeem the Senior Notes, which mature on May 15,
2026. See Item
       303(a) of Regulation S-K.
        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 Al Pavot at 202-551-3738 or Terence
O'Brien at 202-
551-3355 if you have questions regarding comments on the financial statements
and related
matters. Please contact Juan Grana at 202-551-6034 or Katherine Bagley at
202-551-2545
with any other questions.
 May 21, 2025
Page 3



               Sincerely,

               Division of Corporation Finance
               Office of Industrial Applications and
               Services