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                               May 6, 2021

       Ed Kilroy
       Chief Executive Officer
       MedAvail Holdings, Inc.
       6665 Millcreek Drive, Suite 1
       Mississauga, Ontario, Canada L5N 5M4

                                                        Re: MedAvail Holdings,
Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed April 19,
2021
                                                            File No. 333-255347

       Dear Mr. Kilroy:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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.

       Registration Statement on Form S-1 filed April 19, 2021

       Incorporation of Certain Information by Reference, page 57

   1.                                                   Please revise your
prospectus to remove this section and include all of the disclosure
                                                        required by Form S-1.
In this regard, we note that the registered entity disposed of
                                                        substantially all of
its assets and liabilities in a spin-off transaction in November 2020
                                                        prior to completing the
merger with MedAvail, Inc. Accordingly you do not meet the
                                                        requirements of General
Instruction VII.D.1(b) of Form S-1 at this time.
               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.
 Ed Kilroy
MedAvail Holdings, Inc.
May 6, 2021
Page 2

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Jeffrey Gabor at 202-551-2544 or Joe McCann at
202-551-6262 with
any questions.



                                                           Sincerely,
FirstName LastNameEd Kilroy
                                                           Division of
Corporation Finance
Comapany NameMedAvail Holdings, Inc.
                                                           Office of Life
Sciences
May 6, 2021 Page 2
cc:       Eric Hsu, Esq.
FirstName LastName