February 6, 2025

Faith Zaslavsky
Chief Executive Officer
IMAC Holdings, Inc.
3401 Mallory Lane, Suite 100
Franklin, TN 37067

       Re: IMAC Holdings, Inc.
           Amendment No. 1 to Registration Statement on Form S-1
           Filed January 24, 2025
           File No. 333-280184
Dear Faith Zaslavsky:

     We have reviewed your amended registration statement and have the
following
comments.

        Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a 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 letter, we may have additional comments.

Amendment No. 1 to Registration Statement on Form S-1
Cover Page

1.     We note your disclosure on page 5 that on January 21, 2025, you received
notice from
       Nasdaq that you were no longer in compliance with the minimum
stockholders    equity
       requirement of $2.5 million for continued listing on the Nasdaq Capital
Market under
       Listing Rule 5550(b)(1), and as a result, that your common stock would
be scheduled
       for delisting from Nasdaq and suspended from trading at the opening of
business on
       January 30, 2025. We also note your disclosure that you may request an
appeal of this
       determination to the Nasdaq hearings panel by January 28, 2025 to
prevent your
       common stock from being delisted and suspended, and that you intend,
within the
       allotted time, to appeal Nasdaq   s determination to the panel. Please
revise to provide
       updated disclosure regarding your appeal to the Nasdaq hearings panel,
and revise
       your cover page to disclose this continued listing deficiency. In your
revised
 February 6, 2025
Page 2

       disclosure, please also discuss the impact of a potential delisting of
your common
       stock on this offering, including that, as disclosed on page 15, it is a
condition
       precedent to commencement that the common stock has not been suspended
by
       Nasdaq.
Prospectus Summary, page 2

2.     We note your disclosure on page 2 that you have entered into agreements
with
       Vanderbilt and GMU to transfer the Original Proteomics Licenses and to
extend the
       scope of the license from GMU to Europe and Canada. Please revise to
disclose the
       material terms of your agreements with Vanderbilt and GMU. Please also
file the
       agreements as exhibits to your registration statement. Refer to Item
601(b)(10) of
       Regulation S-K.
3.     We note your disclosure on page 2 that you "expect to increase levels of
potential
       revenue with high volume sample analysis," and that "the expansion of
scope to
       Europe and Canada and, potentially in the future, other regions,
provides a greater
       opportunity to achieve higher volume sample analysis." We also note your
disclosure
       that the expanded license protects you from the risk of potential
competitors in Europe
       that could compete in the proteomics analysis business. Please revise to
further
       discuss your expansion into Europe and Canada, including a more granular
       breakdown of the geographic markets where your products are sold, and
the timing for
       your expansion into these and any other future markets where you intend
to
       commercialize your products. In this regard, we note your disclosure on
page 3 that
       "[t]he currently available Ignite RPPA Assay for Breast Cancer will be
followed by
       the Ignite RPPA Pan-Tumor Assay 1.0, expected to launch in 2025 to
include ovarian,
       endometrial, and head & neck cancers. The test is expected to expand
further in 2026
       to the Ignite RPPA Pan-Tumor Assay 2.0 to support the treatment of
colorectal,
       prostate, pancreatic, lung, and other solid tumor cancer indications."
Please also revise
       to briefly explain how your products are regulated in Canada and Europe,
and clarify
       how the expanded licenses protect you from the risk of potential
competitors in
       Europe.
4.     We note your disclosure on page 2 that your commercially available LDT,
the Ignite
       RPPA Assay for Breast Cancer, is currently being utilized by oncologists
across the
       United States. Please revise your disclosure to clarify whether the
Ignite RPPA and
       any assays that you plan to commercialize in the future are or will be
subject to FDA
       regulatory approvals. In your revised disclosure, please consider the
applicability of
       the final rule issued by the FDA on May 6, 2024, related to LDTs. Make
conforming
       changes to your risk factors.
General

5.     Please revise to include executive compensation disclosure for the
fiscal year ended
       December 31, 2024. Refer to Item 11 of Form S-1 and Item 402 of
Regulation S-K.
 February 6, 2025
Page 3

       Please contact Juan Grana at 202-551-6034 or Katherine Bagley at
202-551-2545
with any questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Industrial
Applications and
                                                        Services
cc:   Carol W. Sherman, Esq.