May 7, 2025

Elisa Luqman
Chief Financial Officer
Cardio Diagnostics Holdings, Inc.
311 West Superior Street Suite 444
Chicago, IL 60654

       Re: Cardio Diagnostics Holdings, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2024
           File No. 001-41097
Dear Elisa Luqman:

       We have reviewed your May 7, 2025 response to our comment letter and
have the
following comment.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our April 17,
2025 letter.

Form 10-K for the Fiscal Year Ended December 31, 2024
Item 8. Financial Statements and Supplemental Data
Note 3 - Summary of Significant Accounting Policies, page F-7

1.     We note your response and proposed disclosure to prior comment five and
reissue our
       comment in part. Please confirm that your future filings will include
the ASC 280-10-
       50 disclosure requirements to provide your measure of segment
profit/loss, significant
       segment expense, and other requirements that may be applicable to your
single
       operating segment.
 May 7, 2025
Page 2

       Please contact Bonnie Baynes at 202-551-4924 or Angela Connell at
202-551-3426 if
you have questions regarding comments on the financial statements and related
matters.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Life Sciences