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                             January 15, 2021

       Christopher Ianelli
       Chief Executive Officer
       iSpecimen Inc.
       450 Bedford Street
       Lexington, MA 02420

                                                        Re: iSpecimen Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed December 31,
2020
                                                            File No. 333-250198

       Dear Mr. Ianelli:

             We have reviewed your amended registration statement and have the
following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
December 14, 2020 letter.

       Amendment No. 1 to Registration Statement on Form S-1, filed December
31, 2020

       Prospectus Summary
       COVID-19 Impact, page 8

   1.                                                   We note your response
to comment 3, and your amended disclosure on page 8. With a
                                                        view to understanding
your business and supply chain, please amend your disclosure to
                                                        briefly define
"fully-disabled" and "partially-disabled," and the impact of each on your
                                                        business.
 Christopher Ianelli
FirstName
iSpecimen LastNameChristopher Ianelli
           Inc.
Comapany
January 15,NameiSpecimen
            2021         Inc.
January
Page 2 15, 2021 Page 2
FirstName LastName
Risk Factors
Risks related to our Business
"Challenges or unanticipated costs in establishing . . .", page 20

2.       We note your response to comment 8, and your amended disclosure on
page 20 that "[w]e
         have entered into agreements with two non-exclusive distributors in
the country of Japan
         and will continue to look for distributor partnership opportunities
covering other rest-of-
         world markets." It appears from your disclosure on page 81 that these
agreements are the
         Non-Exclusive Marketing, Sales & Distribution Agreements with BizCom
Japan, Inc. and
         Cosmo Bio Co., Ltd. Please amend your disclosure to include the
minimum annual
         purchase order amount obligation under the terms of the agreement with
BizCom Japan,
         Inc. Please also file these agreements as exhibits to your
registration statement, or tell us
         why you do not believe you are required to do so. See Item 601(b)(10)
of Regulation S-K.
Business
Our Customers, page 75

3.       We note your response to comment 17, and your amended disclosure that
"[w]e continue
         to have and maintain site participation agreements with several
provider partners which
         enable us to offer through our iSpecimen Marketplace, various types of
annotated
         hematologic products that are used in the research and development of
regenerative
         medicine therapies." In an appropriate place in your filing, please
describe the terms of
         these site participation agreements, and file the relevant agreements
as exhibits to your
         registration statement, or tell us why you do not believe you are
required to do so. See
         Item 601(b)(10) of Regulation S-K.
Our Sales Pipeline, page 79

4.       We note your revised disclosure in response to our prior comment
number 20. Please
         revise to disclose how you define "open backlog."
Executive Compensation, page 95

5.       Please update your disclosure in this section to include information
for your latest
         completed fiscal year. See Item 402 of Regulation S-K.
Notes to Financial Statements
Summary of Significant Accounting Policies
Revenue Recognition and Accounts Receivable, page F-35, page F-35

6.       We note your response to our prior comment number 27. We also note
your statement
         that "[t]he hold was specifically related to circumstances whereby the
supplier was not
         able to process the specimens due to COVID-19 shutdowns." Please
further clarify what
         you mean by "the supplier was not able to process the specimens." You
also state "the
         customer requested that the Company hold portions of its orders for a
period of up to six
 Christopher Ianelli
iSpecimen Inc.
January 15, 2021
Page 3
       months." Please clarify whether you or the supplier was holding the
specimens during the
       period of the related bill-and-hold.
7.     We note your response to our prior comment number 29. It appears that
the terms
       "collected and collection" are used in different contexts throughout the
response and
       filing. Specifically, as it relates to the timing of revenue
recognition, please tell us and
       revise to disclose how you define "upon collection." We further note
your discussion of
       how you determined that the specimen has no alternative use and
accordingly revenue
       should be recognized over time. However, it is still not clear to us how
you determined
       that control has transferred to the customer upon collection verses upon
shipment by you
       or receipt by the customer. Please tell us how you considered the
guidance in ASC 606-1-
       25-25. Please be detailed and specific in your response.
       You may contact Aamira Chaudhry at (202) 551-3389 or Lyn Shenk at (202)
551-3380 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Katherine Bagley at (202) 551-2545 or Dietrich King at (202) 551-8071
with any other
questions.



                                                             Sincerely,
FirstName LastNameChristopher Ianelli
                                                             Division of
Corporation Finance
Comapany NameiSpecimen Inc.
                                                             Office of Trade &
Services
January 15, 2021 Page 3
cc:       Tamar Donikyan
FirstName LastName