November 20, 2018

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

       Re: Youngevity International, Inc.
           Amendment No. 1 to Registration Statement on Form S-3
           Filed November 13, 2018
           File No. 333-227866

Dear Mr. Wallach:

       We have reviewed your amended registration statement and have the
following
comment. In our comment, 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 comment applies 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 this comment, we may have additional comments. Unless we
note
otherwise, our reference to a prior comment is to a comment in our November 5,
2018 letter.

Amendment No. 1 to Registration Statement on Form S-3

General

1.     We note your response to comment 3 that your true-up shares are
substantially the same as
       earn out shares, which are eligible for resale on Form S-3 per Question
116.05 of our
       Securities Act Forms Compliance and Disclosure Interpretations. Please
note that the
       accommodation in Question 116.05 is limited to earn out provisions in
business
       combination transactions. Please remove the true-up shares as they may
not be registered
       at this time or provide us with your analysis showing how you determined
that there was a
       completed private placement under Section 4(a)(2) of Securities Act
1933. Refer to
       Question 116.19 of our Securities Act Forms Compliance and Disclosure
Interpretations
       for guidance.
 Stephan Wallach
Youngevity International, Inc.
November 20, 2018
Page 2




       Please 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 20, 2018 Page 2                                   Office of Consumer
Products
FirstName LastName