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Youngevity International, Inc.
2400 Boswell Road
Chula Vista, California 91914
December 6,
2018
VIA EDGAR
United
States Securities
and Exchange
Commission
Division of
Corporation Finance
100 F Street,
N.E.
Washington, D.C.
20549
Attention: Jennifer
Lopez
Staff Attorney
Re:
Youngevity International, Inc.
Registration Statement on Form
S-3
File No: 333-227866
Ladies
and Gentlemen:
Youngevity
International, Inc. (the “Registrant”) hereby requests that
the United States Securities and Exchange Commission (the
“Commission”)
take appropriate action to cause the above-referenced Registration
Statement on Form S-3 (File No. 333-227866), to become effective on
Monday, December 10, 2018,
at 4:00 p.m., Eastern Time,
or as soon thereafter as is practicable.
The
Registrant hereby authorizes its counsel, Leslie Marlow, Esq. or
Patrick J. Egan, Esq. of Gracin &
Marlow, LLP, to orally modify or withdraw this request for
acceleration. Please contact Ms. Marlow at (516) 496-2223 or (212)
907-6457 or Mr. Egan at (914) 557-5574 or (212) 907-6457 with any
questions you may have concerning this request, and please notify
her when this request for acceleration has been
granted.
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Very truly
yours,
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Youngevity
International, Inc.
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By: /s/ Stephan Wallach
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Title: Chief
Executive Officer
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cc:
David
Briskie, Chief Financial Officer of Youngevity International,
Inc.
Leslie Marlow, Esq., Gracin & Marlow, LLP
Patrick J. Egan, Esq., Gracin & Marlow, LLP
