United States securities and exchange commission logo





                          May 10, 2021

       Paul C. Tarell
       Chief Financial Officer
       GAIA, INC
       833 West South Boulder Road
       Louisville, Colorado 80027

                                                        Re: GAIA, INC
                                                            Registration
Statement on Form S-3
                                                            Filed May 3, 2021
                                                            File No. 333-255734

       Dear Mr. Tarell:

              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 Taylor
Beech at 202-551-4515 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Trade & Services
       cc:                                              Polly Swartzfager, Esq.