November 18, 2024 Ted Karkus Chairman of the Board, Chief Executive Officer and Director ProPhase Labs, Inc. 711 Stewart Avenue, Suite 200 Garden City, NY 11530 Re: ProPhase Labs, Inc. Registration Statement on Form S-3 Filed November 12, 2024 File No. 333-283182 Dear Ted Karkus: 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 Daniel Crawford at 202-551-7767 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Michael Lee, Esq.