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                             May 20, 2024

       Amro Albanna
       Chief Executive Officer
       Aditxt, Inc.
       737 N. Fifth Street, Suite 200
       Richmond, VA 23219

                                                        Re: Aditxt, Inc.
                                                            Amendment No. 3 to 
Registration Statement on Form S-1
                                                            Filed May 14, 2024
                                                            File No. 333-276588

       Dear Amro Albanna:

                                                        We have reviewed your 
amended registration statement and have the following comment.

              Please respond to this letter by amending your registration 
statement and providing the
       requested information. If you do not believe this comment applies 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 this letter, we may have additional comments. 
Unless we note otherwise,
       any reference to a prior comment is to the comment in our February 15, 
2024 letter.

       Amendment No. 3 to Registration Statement on Form S-1

       Notes to the Consolidated Financial Statements
       Note 3 - Summary of Significant Accounting Policies
       Investments, page F-12

   1.                                                   We note your disclosure 
that you appear to have purchased equity investments in the
                                                        amount of $22,711,211, 
which corresponds to an investment in Evofem on your balance
                                                        sheet. Please provide 
us your analysis of accounting for this investment under the cost
                                                        method and how you 
concluded that you do not exercise significant influence over
                                                        Evofem such that 
financial statements pursuant to Rule 3-09 of Regulation S-X would be
                                                        required. In addition, 
please confirm you continue to believe the acquisition of Evofem is
                                                        not probable such that 
financial statements and pro forma information are not required
                                                        under Rule 3-05 and 
Article 11 of Regulation S-X.
 Amro Albanna
Aditxt, Inc.
May 20, 2024
Page 2

       Please contact Tracie Mariner at 202-551-3744 or Mary Mast at 
202-551-3613 if you
have questions regarding comments on the financial statements and related 
matters. Please
contact Jimmy McNamara at 202-551-7349 or Tim Buchmiller at 202-551-3635 with 
any other
questions.



                                                        Sincerely,
FirstName LastNameAmro Albanna
                                                        Division of Corporation 
Finance
Comapany NameAditxt, Inc.
                                                        Office of Life Sciences
May 20, 2024 Page 2
cc:       Sean F. Reid, Esq.
FirstName LastName