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Youngevity International, Inc.
2400 Boswell Road
Chula Vista, California 91914
December 26,
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: 333-228983
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. 333-228983), to become effective on
Wednesday, December 26,
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:
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David
Briskie, Chief Financial Officer of Youngevity International,
Inc.
Leslie
Marlow, Esq., Gracin & Marlow, LLP
Patrick
J. Egan, Esq., Gracin & Marlow, LLP
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