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                           April 29, 2024

       Brandon LaVerne
       Chief Executive Officer
       Ontrak, Inc.
       333 S. E. 2 nd Avenue, Suite 2000
       Miami, FL 33131

                                                        Re: Ontrak, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed April 22,
2024
                                                            File No. 333-278848

       Dear Brandon LaVerne:

              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 Industrial Applications and

                           Services
       cc:                                              John Tishler