United States securities and exchange commission logo





                 June 9, 2022

       Mark Doerr
       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-3
                                                            Filed on June 3,
2022
                                                            File No. 333-265402

       Dear Mr. Doerr:

              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 Janice Adeloye at 202-551-3034 or Cara Wirth at
202-551-7127 with any
       questions.




                 Sincerely,


                 Division of Corporation Finance

                 Office of Trade & Services