November 5, 2018

Stephan Wallach
Chief Executive Officer
Youngevity International, Inc.
2400 Boswell Road
Chula Vista, California 91914

       Re: Youngevity International, Inc.
           Registration Statement on Form S-3
           Filed October 17, 2018
           File No. 333-227866

Dear Mr. Wallach:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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 this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Form S-3 filed on October 17, 2018

General

1.     We note that Exhibit 99.1 of your Current Report on Form 8-K filed
September 21, 2018
       discloses that you have entered the cannabis industry. Please revise
your registration
       statement to clearly describe your business in the cannabis industry and
the risks to the
       company from engaging in this business, including possible law
enforcement
       consequences under federal and state laws.
2.     We note that you are attempting to register the resale by the selling
stockholders of
       1,394,726 shares of common stock issuable upon the exercise of Series C
Preferred Stock
       Warrants. Please be advised that we believe it is premature to register
for resale shares of
 Stephan Wallach
FirstName LastNameStephan Wallach
Youngevity International, Inc.
Comapany 5, 2018
November NameYoungevity International, Inc.
November 5, 2018 Page 2
Page 2
FirstName LastName
         your common stock underlying Series C Preferred Stock Warrants that
are not yet
         outstanding. In this regard, we note that the Warrants will be issued
upon the exercise of
         the Series C Preferred Stock that is voluntarily converted to shares
of your Common
         Stock. Accordingly, please amend your registration statement to remove
from registration
         the resale of any shares of common stock that are issuable upon
conversion of shares of
         your Series C Preferred Stock Warrants that are not yet outstanding.
Alternatively, please
         provide us with your analysis as to why it is appropriate to register
the resale of common
         stock underlying the Warrants. Refer generally, to Question 134.01 of
our Securities Act
         Sections Compliance and Disclosure Interpretations.
3.       We note that you are registering for resale 367,805 True-up Shares of
common stock. We
         also note that you will issue "to the PIPE Selling Stockholders
additional shares of [y]our
         Common Stock (the "True-up Shares") within the expiration of the
Subscription Pricing
         Period" and that such issuance will occur "in the event that the
average of the 15 lowest
         closing prices for [y]our Common Stock during the period beginning on
date of execution
         of such Purchase Agreement and ending on the date 90 days from the
effective date of the
         registration statement...is less than $4.75 per share." In this
regard, it appears that some of
         the shares being registered for resale have not been issued to the
selling shareholder.
         Provide us with an analysis as to why you believe that the selling
shareholder is
         irrevocably bound to purchase, and is at market risk for, the True-up
shares being
         registered for resale.

         Please note that if the selling shareholder was not irrevocably bound
to purchase the
         shares and at market risk with respect to those shares at the time you
register the resale,
         the private placement of those shares has not been completed, and you
will not be able to
         register the resale with respect to those shares. In that event, you
will have to remove
         those shares from this registration statement and, if desired, file a
new registration
         statement to register those shares no sooner than the date that the
selling shareholder
         becomes irrevocably bound to purchase and is at market risk with
respect to those shares.
         For guidance, refer to Question 139.11 of our Compliance and
Disclosure Interpretations
         relating to Securities Act Sections.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
 Stephan Wallach
Youngevity International, Inc.
November 5, 2018
Page 3

       You may contact Jennifer L pez, Staff Attorney, at 202-551-3792 or
Lilyanna Peyser,
Special Counsel, at 202-551-3222 with any other questions.



FirstName LastNameStephan Wallach                        Sincerely,
Comapany NameYoungevity International, Inc.
                                                         Division of
Corporation Finance
November 5, 2018 Page 3                                  Office of Consumer
Products
FirstName LastName