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                             January 25, 2024

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

                                                        Re: Aditxt, Inc.
                                                            Registration 
Statement on Form S-1
                                                            Filed January 18, 
2024
                                                            File No. 333-276588

       Dear Amro Albanna:

              We have conducted a limited review of your 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.

       Registration Statement on Form S-1

       General

   1.                                                   It appears that you are 
not eligible to incorporate by reference into your Form S-1, given
                                                        that you have not filed 
your annual report for your most recently completed fiscal year.
                                                        Please revise your 
registration statement to provide all disclosure required by Form S-1 or
                                                        otherwise advise. See 
General Instruction VII.C to Form S-1.
               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.

              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.
 Amro Albanna
Aditxt, Inc.
January 25, 2024
Page 2

       Please contact Jimmy McNamara at 202-551-7349 or Tim Buchmiller at 
202-551-3635
with any questions.



                                                      Sincerely,
FirstName LastNameAmro Albanna
                                                      Division of Corporation 
Finance
Comapany NameAditxt, Inc.
                                                      Office of Life Sciences
January 25, 2024 Page 2
cc:       Sean F. Reid, Esq.
FirstName LastName