TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo February 1, 2023 Bernaldo Dancel Chief Executive Officer NAVA HEALTH MD, LLC 9755 Patuxent Woods Drive, Suite 100 Columbia, Maryland 21046 Re: NAVA HEALTH MD, LLC Amendment No. 2 to Registration Statement on Form S-1 Filed January 30, 2023 File No. 333-268022 Dear Bernaldo Dancel: 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. Amendment No. 2 to Registration Statement on Form S-1, Filed January 30, 2023 Risk Factors, page 11 1. We note recent instances of extreme stock price run-ups followed by rapid price declines and stock price volatility seemingly unrelated to company performance following a number of recent initial public offerings, particularly among companies with relatively smaller public floats. Revise to include a separate risk factor addressing the potential for rapid and substantial price volatility and any known factors particular to your offering that may add to this risk and discuss the risks to investors when investing in stock where the price is changing rapidly. Clearly state that such volatility, including any stock-run up, may be unrelated to your actual or expected operating performance and financial condition or prospects, making it difficult for prospective investors to assess the rapidly changing value of your stock. Bernaldo Dancel NAVA HEALTH MD, LLC February 1, 2023 Page 2 Use of Proceeds, page 42 2. We note in your free writing prospectus filed January 30, 2023, you state that one of your uses of proceeds for this offering is strategic acquisitions. Please revise the Registration Statement to reflect this or advise. You may contact Tracie Mariner at 202-551-3744 or Al Pavot at 202-551-3738 if you have questions regarding comments on the financial statements and related matters. Please contact Margaret Schwartz at 202-551-7153 or Laura Crotty at 202-551-7614 with any other questions. Sincerely, FirstName LastNameBernaldo Dancel Division of Corporation Finance Office of Industrial Applications and Comapany NameNAVA HEALTH MD, LLC Services February 1, 2023 Page 2 cc: Rachel M. Jones, Esq. FirstName LastName