February 13, 2025

VIA EDGAR AND EMAIL

U.S. Securities and Exchange Commission

Division of Corporation Finance, Office of Industrial Applications and Services

100 F Street, NE

Washington, D.C. 20549

Dear Mr. Grana and Ms. Bagley:

In response to your oral comments delivered by telephone to the Company’s counsel on February 12, 2025 (the “Oral Comments”), please see below IMAC’s responses to your comments and revisions in connection there with included in Amendment No. 3 to the Registration Statement on Form S-1, File No. 333-280184 as filed with the Securities and Exchange Commission on February 13, 2025 (“S-1 Amendment No. 3”). We have included your comments in italics for reference.

Amendment No. 2 to Registration Statement on Form S-1

General

1. Resubmit Exhibits 10.35 and 10.36 in a format that is text-searchable.

RESPONSE: In response to Oral Comment No. 1, the Company has filed Exhibits 10.35 and 10.36 with the S-1 Amendment No. 3 in a format that is text-searchable.

Prospectus Summary, page 3

2. Provide more information about the clinical data referred to in the Strategy section to substantiate the disclosure about such clinical data.

RESPONSE: In response to Oral Comment No. 2, the Company has revised the disclosure in S-1 Amendment No. 3 to provide fulsome disclosure regarding the clinical data. The Company is hereby submitting marked pages set forth on Exhibit A hereto showing proposed changes to the S-1 Amendment No. 3.

Securities and Exchange Commission

February 13, 2025

Page 2

Prospectus Summary, page 4

3. Revise the disclosure on page 4 to state that the Company cannot guarantee it will meet the requirements of such new rules or obtain any requisite approvals required by new rules.

RESPONSE: In response to Comment No. 3, the Company has revised the disclosure in S-1 Amendment No. 3 to disclaim any implied guarantee that the Company will be able to meet the requirements of any applicable future rule. The Company is hereby submitting marked pages set forth on Exhibit B hereto showing proposed changes to the S-1 Amendment No. 3.

If you require any further information or have additional questions, please contact me at (818) 613-0151 or our counsel, Carol W. Sherman of Kelley Drye & Warren LLP, at (212) 808-5038.

EXHIBIT A

Exhibit B