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                                                               July 19, 2024

Jeffrey Holman
Chief Executive Officer
Healthy Choice Wellness Corp.
3800 North 28th Way
Hollywood, FL 33020

       Re: Healthy Choice Wellness Corp.
           Amendment No. 5 to Registration Statement on Form S-1
           Filed June 26, 2024
           File No. 333-274435
Dear Jeffrey Holman:

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

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe a 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 references to prior comments are to comments in our June 21, 2024 letter.

Amendment No. 5 to Form S-1
Prospectus Cover Page, page ii

1.     Please disclose prominently on the prospectus cover page that Healthy
Choice Wellness
       Corp will be spun-off from Healthier Choices Management Corp, which
currently is
       quoted on the OTC Pink at $0.0001 and has a 52-week range of $0.0000 -
$0.0001.
       Disclose that HCMC prior to the spin-off is substantially the same
company as HCWC
       after the spin-off, yet the offering price of $9.00 to $11.00 is
substantially greater than the
       OTC Pink quotation of $0.0001.
Risk Factors, page 4

2.     You disclose that one of the factors considered in determining the
offering price was the
       valuation prepared by Newbridge Securities Corporation in February 2024.
Please add
       risk factor disclosure in the front of the risk factors section
indicating that the price of the
 July 19, 2024
Page 2

       offering and the value of HCMC as reported in the valuation report are
substantially
       higher than the current quotation price of Healthier Choices Management
of $0.0001 on
       OTC Pink. Disclose the comparable companies used in the valuation
report, such as
       Costco Wholesale Corporation, Sysco Corporation and Casey's General
Stores, Inc. and
       indicate the annual revenues and market capitalization for these
comparable companies
       and how this compares to HCWC. Discuss the difference in industry focus
of companies
       such as Costco with companies like HCMC, as HCMC appears to operate in a
more
       specialized market than Costco. Indicate the risks of using these
companies as
       comparables in the valuation analysis, including in the discounted cash
flow analysis, and
       how this could have influenced or impacted the implied equity value of
HCMC. Disclose
       the risk to investors if the market value of HCMC, once listed on the
exchange, is
       significantly lower than the value in the valuation report.
Neither we nor HCMC can assure you as to the trading price..., page 13

3.     Please revise here to disclose the most recent quotation price of HCMC
on OTC Pink as
       compared to the price range for this offering of $9.00 to $11.00.
Quantify the trading price
       of HCMC if it is less than the quotation price of HCMC prior to the
Spin-Off, as you
       disclose is possible. Indicate that, aside from certain intellectual
property, the business of
       HCMC before the spin-off and HCWC after the spin-off are identical.
Elsewhere that you
       discuss the trading price or market price of HCWC, indicate that its
pre-spin-off quotation
       on OTC Pink is $0.0001.
       Please contact Suying Li at 202-551-3335 or Joel Parker at 202-551-3651
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Scott Anderegg at 202-551-3342 or Erin Jaskot at 202-551-3442 with any other
questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Trade &
Services
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