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                             February 14, 2023

       Kimball Carr
       Chief Executive Officer
       Inspire Veterinary Partners, Inc.
       780 Lynnhaven Parkway
       Suite 400
       Virginia Beach, VA 23452

                                                        Re: Inspire Veterinary
Partners, Inc.
                                                            Amendment No. 3 to
Draft Registration Statement on Form S-1
                                                            Submitted January
30, 2023
                                                            Amendment No. 4 to
Draft Registration Statement on Form S-1
                                                            Submitted February
2, 2023
                                                            CIK No.: 0001939365

       Dear Kimball Carr:

             We have reviewed your amended draft 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 providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       January 21, 2023 letter.

       Draft Registration Statement on Form S-1 Filed on January 30, 2023 and
February 2, 2023

       Prospectus Summary, page 1

   1.                                                   We refer to your
revised disclosure that you also provide equine care as of December
                                                        2022. To the extent
correct, please revise to balance such information by explaining that
                                                        only one location
provides equine care, and that the other locations are small animal
                                                        practices.
 Kimball Carr
FirstName  LastNameKimball     Carr
Inspire Veterinary Partners, Inc.
Comapany14,
February   NameInspire
             2023        Veterinary Partners, Inc.
February
Page  2 14, 2023 Page 2
FirstName LastName
Risk Factors
The animal health industry is highly competitive, page 19

2.       You state in this revised disclosure that you believe many of your
competitors are
         conducting R&D activities in areas served by your products and or
services, and that you
         also face competition from manufacturers of drugs globally, as well as
producers of
         nutritional health products and animal health service providers.
Please expand your
         discussion to further explain these risks. For example, explain which
R&D activities your
         competitors are conducting and how this may affect competition for
your products and
         services.
Selling Stockholders, page 28

3.       We note your revisions in response to our prior comment 4 and your
statement that the
         disclosure in this section is based on 6,553,632 shares of Class A
common stock and
         4,300,000 shares of Class B common stock expected to be outstanding
upon the
         consummation of the primary offering, and assumes the conversion of
all outstanding
         convertible debt and the exercise of all outstanding warrants.
However, your disclosures
         elsewhere, including on pages 8 and 24, disclose that there will be
10,853,632 shares of
         Class A common stock outstanding after the offering. Please revise to
address the
         discrepancy. In addition, for each selling shareholder, except with
respect to owned
         outstanding shares of Class A common stock, please revise each
shareholder's
         corresponding footnote to clearly disclose the anticipated number of
shares of Class A
         common stock to be owned (e.g., that the share amount in the table
reflects a specified
         number of shares of Class A common stock upon conversion of
convertible promissory
         notes). Also add a discussion explaining how you made such
calculations, (e.g., assuming
         a specified initial public offering price and a corresponding assumed
conversion price). In
         this regard, we note the statement in footnote 28 that only 878,790
shares of common
         stock are outstanding. Ensure that the information presented in this
section is as of a
         recent date. Also explain why you have indicated that certain
shareholders will hold a
         certain percentage of shares after the offering, but you have not
included the number of
         shares owned in the "Total Shares" column.
4.       We refer to the penultimate paragraph on page 30, and note that the
disclosures in this
         revised table and in the revised beneficial ownership table indicates
that certain
         shareholders subject to a lock-up, such as Messrs. Carr, Lau, and
Marten, and Best Future
         Investment, are expected to sell shares in the secondary offering. We
note that you state
         on page 31 that the offering by the selling stockholders will remain
open for 180 days
         following the date of the prospectus, and that these shareholders who
are subject to a lock-
         up are subject to such lock-up for the same duration and would need
the underwriter's
         prior written consent in order to sell. For each shareholder subject
to the lock-up, please
         include a footnote next to the amount and percentage to be owned by
such shareholder to
         disclose any consent that the underwriter has already provided.
 Kimball Carr
FirstName  LastNameKimball     Carr
Inspire Veterinary Partners, Inc.
Comapany14,
February   NameInspire
             2023        Veterinary Partners, Inc.
February
Page  3 14, 2023 Page 3
FirstName LastName
Summary of Results of Operations, page 40

5.       We note your response to comment 11. Pursuant to Item 303(b)(2)(iii)
of Regulation S-K,
         please separately quantify the extent to which each material factor
contributed to changes
         in revenue. In this regard, we would expect quantification of the
extent to which price
         increases contributed to an increase in revenue separately from the
extent to which volume
         decreases resulted in a decrease in revenue.
6.       In regards to your presentation of average daily service revenue and
average daily product
         revenue, please provide the following disclosures:
             How the metric is calculated, including any estimates or
assumptions underlying
              the metric or its calculation;
             The reasons why the metric provides useful information to
investors; and
             How management uses the metric.
         Refer to SEC Release No. 33-10751.
Management and Board of Directors, page 60

7.       We note that you have listed director nominees, and that your footnote
disclosure on page
         60 states that such nominees are anticipated to become effective upon
consummation of
         the underwritten primary offering. However, we note that the consents
you have filed as
         exhibits for such director nominees state that their appointment as
directors will take
         effect upon the effective date of the registration statement. Please
revise to reconcile the
         discrepancies, and if the director nominees will become directors on
the effective date of
         the registration statement, please clarify that you will file a
pre-effective amendment that
         includes the signatures of a majority of the board, as then in effect,
or advise.
8.       We refer to your revised disclosure on page 65, and note that you
state that there are three
         female directors as of January 30, 2023. However, based on your
disclosures elsewhere,
         including your signature page and your disclosures of your management,
this information
         does not appear to be accurate. Please revise accordingly.
Executive and Director Compensation, page 67

9.       We refer to your revised disclosures in response to prior comment 9.
Please explain
         why you have disclosed no compensation paid to Messrs. Keiser and Lau.
Item 402(m) of
         Regulation S-K provides that all compensation paid to named executive
officers shall be
         reported pursuant to the Item, even if also called for by another
requirement, including
         transactions between you and a third party where a purpose of the
transaction is to furnish
         compensation to any such named executive officer or director. In this
regard, we note that
         you have consulting agreements with Star Circle Advisory Group, owned
and controlled
         by your directors, including Mr. Lau, and Blue Heron Consulting,
partially owned by Mr.
         Stith Keiser.
10.      We refer to your revised disclosure on page 70 that Mr. Carr was
granted a cashless
         warrant on September 1, 2022 by the board of directors in
consideration of Mr. Carr's
 Kimball Carr
Inspire Veterinary Partners, Inc.
February 14, 2023
Page 4
         personal guaranty of your loans. Please revise to include the grant of
warrant in your
         compensation table. Refer to Item 402(n).
Security Ownership of Certain Beneficial Owners and Management, page 69

11.      We refer to your response to prior comment 3, which states that the
share distributions
         by Wilderness Trace has not yet occurred. Since such share
distributions have not yet
         occurred, please explain why the ownership of Wildnerness Trace is not
reflected in this
         table, or revise accordingly.
12.      We note your revised disclosure that the table reflects beneficial
ownership information as
         of December 31, 2022, and that the voting power ownership information
reflects a total of
         10,853,632 shares of common stock outstanding, which includes both
shares of Class A
         and Class B common stock. However, your revised disclosure on page 8
indicates that
         after the offering, there will be 10,853,632 shares of Class A common
stock outstanding.
         Please revise your disclosures here to clearly show information as of
a recent date. Also
         revise the table to disclose the ownership information after the
consummation of the
         primary offering and to explain the expected conversions.
Item 15. Recent Sales of Unregistered Securities, page II-2

13.      We note your response to our prior comment 13 and that you made Form D
filings on
         January 27, 2023. It continues to appear that you have not filed a
corresponding Form D
         for certain of these offerings. For example, it does not appear that a
Form D was filed for
         the November 2022 Bridge Financing with Target and 622 Capital, LLC.
Financial Statements, page F-1

14.      We are continuing to evaluate your waiver request and response to
comment 10.
15.    We note your response to comment 11 and that you intend to to file an
amended S-1
       which will include fiscal year 2022 audited consolidated financial
statements. It is not
       clear why you indicated that the inclusion of the 2022 audited financial
statements will
       result in the exclusion of any preacquisition audited financial
statements of acquirees
       pursuant to Rule 3-05 of Regulation S-X based on your application of SAB
Topic 1.J. For
       purposes of Rule 3-05 of Regulation S-X and correspondingly SAB Topic
1.J, we remind
       you that you must evaluate business acquisitions that occurred during
the most recent
       fiscal year or subsequent interim period. Given that you had multiple
acquisitions during
       2022 including The Pony Express Veterinary Hospital in September 2022
and the
       Williamsburg Animal Clinic in December 2022, as previously requested,
please provide
FirstName LastNameKimball Carr
       us with your detailed application of the guidance of SAB Topic 1.J which
led to your
Comapany    NameInspire
       determination   thatVeterinary Partners,
                            preacquisition      Inc.financial statements would
not be required for
                                           audited
       your
February  14,acquirees.
              2023 Page 4
FirstName LastName
 Kimball Carr
FirstName  LastNameKimball     Carr
Inspire Veterinary Partners, Inc.
Comapany14,
February   NameInspire
             2023        Veterinary Partners, Inc.
February
Page  5 14, 2023 Page 5
FirstName LastName
Note 7. Stockholders Equity, page F-23

16.      We remind you of comment 34 of our letter dated November 21, 2022 and
your response
         dated December 7, 2022 in which you indicated that you will provide an
explanation for
         the determination of the fair value of the common stock underlying
your equity issuances
         and the reasons for the differences between recent valuations of your
common stock and
         the estimated offering price. Given that you have included an
estimated offering price,
         please provide us with this explanation.
Exhibits

17.      We note your revisions in response to our prior comment 15 and reissue
in part. We note
         your disclosure in the exhibit index key that certain schedules and
exhibits have
         been omitted pursuant to Item 601(b)(10)(iv) of Regulation S-K. To the
extent you intend
         to redact information from any exhibit pursuant to Item 601(b)(10)(iv)
of Regulation S-K,
         please revise the applicable footnote to state that certain
information has been excluded
         from relevant exhibits because it is both not material and the type of
information that the
         registrant treats as private or confidential. Additionally, please
include a prominent
         statement on the first page of each redacted exhibit that certain
identified information has
         been excluded from the exhibit because it is both not material and is
the type that the
         registrant treats as private or confidential, and to include brackets
to indicate where the
         information is omitted from the filed version of the exhibit.
18.      We refer to your revised disclosures regarding the convertible
promissory notes issued to
         various individuals and entities as partial consideration for your
acquisitions. To the extent
         any such note will not convert automatically upon the completion of
the primary offering,
         please file such agreement or form of such agreement as an exhibit.
       You may contact Nudrat Salik at 202-551-3692 or Al Pavot at 202-551-3738
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Jordan Nimitz at 202-551-5831 or Dorrie Yale at 202-551-8776 with any other
questions.



                                                                Sincerely,

                                                                Division of
Corporation Finance
                                                                Office of
Industrial Applications and
                                                                Services
cc:      Joe Laxague, Esq.