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United States securities and exchange commission logo
June 14, 2024
Faith Zaslavsky
Chief Executive Officer
IMAC Holdings, Inc.
3401 Mallory Lane, Suite 100
Franklin, TN 37067
Re: IMAC Holdings, Inc.
Preliminary Proxy
Statement on Schedule 14A
Filed June 6, 2024
File No. 001-38797
Dear Faith Zaslavsky:
We have limited our review of your filing to the 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 within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Preliminary Proxy Statement on Schedule 14A filed June 6, 2024
General
1. We note that the
preliminary proxy statement relates to the solicitation of stockholder
approval for the
potential issuance of an excess of 19.99% of your outstanding common
stock under your
outstanding Series D Preferred Stock and Series E Preferred Stock,
which were issued in
connection with the acquisition of the assets of Theralink. Please
revise the proxy
statement to provide all of the information required by
Item 14 of Schedule
14A.
2. Please provide the
financial information required by Items 14(b)(11) and 14(c)(2) of
Schedule 14A, including
audited financial statements for the two most recent fiscal years
for Theralink, and pro
forma financial information accounting for the acquisition of the
assets of Theralink.
Please also provide interim unaudited financial statements, as
applicable. Refer to
Rules 8-04 and 8-05 and Article 11 of Regulation S-X.
Faith Zaslavsky
IMAC Holdings, Inc.
June 14, 2024
Page 2
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 Juan Grana at 202-551-6034 or Jane Park at 202-551-7439
with any other
questions.
Sincerely,
FirstName LastNameFaith Zaslavsky Division of
Corporation Finance
Office of Industrial
Applications and
Comapany NameIMAC Holdings, Inc.
Services
June 14, 2024 Page 2
cc: Carol W. Sherman, Esq.
FirstName LastName