United States securities and exchange commission logo September 30, 2022 Jeffrey Ervin Chief Executive Officer IMAC Holdings, Inc. 1605 Westgate Circle Brentwood, TN 37027 Re: IMAC Holdings, Inc. Registration Statement on Form S-3 Filed September 26, 2022 File No. 333-267622 Dear Mr. Ervin: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Jessica Ansart at 202-551-4511 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Spencer G. Feldman, Esq.