November 18, 2024

Dayton Judd
Chief Executive Officer
FitLife Brands, Inc.
5214 S. 136th Street
Omaha, NE 68137

       Re: FitLife Brands, Inc.
           Registration Statement on Form S-3
           Filed November 14, 2024
           File No. 333-283228
Dear Dayton Judd:

       This is to advise you that we have not reviewed and will not review your
registration
statement.

        Please refer to Rules 460 and 461 regarding requests for acceleration.
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 Joshua Gorsky at 202-551-7836 with any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Life
Sciences
cc:   Jack Kennedy, Esq.