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October 11, 2013

VIA EDGAR

Tia L. Jenkins

Senior Assistant Chief Accountant

Division of Corporate Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:  RadNet, Inc.

Form 10-K for the Year Ended December 31, 2012

Filed March 18, 2013

Amendment No. 1 to Form 10-K for the Year Ended
December 31, 2012

Filed April 1, 2013

File No. 001-33307

Dear Ms. Jenkins:

We acknowledge receipt
of the letter of comment dated September 20, 2013 from the Staff of the Division of Corporation Finance with regard to the above-referenced
filings. We have repeated the Staff’s comment below, followed by our response.

Form 10-K for the Year Ended December
31, 2012

General

1. Please be advised that your correct
file number for Exchange Act reporting purposes is 001-33307.

We confirm that in future
filings we will use the correct file number.

Item 1. Business, page 3

 2. Based on review of historical trends of the last three years, it appears your business experiences
the lowest revenues during the first quarter of each year as indicated by net losses recognized during the first quarters of 2013,
2012 and 2011. In addition, based on the earnings release, you state your first quarter is generally the most challenging quarter
with respect to procedural volumes because of typical seasonality in your business. Please provide a draft to be included in future
filings to address the seasonality of your business, as required by Item 303(a)(3) of Regulation S-K.

U.S. Securities and Exchange Commission

Division of Corporation Finance

October 11, 2013

Page 2

We propose to include a
disclosure in future filings, to the extent appropriate, substantially as follows:

“We typically
experience some seasonality to our business. During the first quarter of each year we generally experience the lowest volumes of
procedures and the lowest level of revenue for any quarter during the year.  This is primarily the result of two factors.
First, our volumes and revenue are typically impacted by winter weather conditions in our northeastern operations.  It is
common for snowstorms and other inclement weather to result in patient appointment cancellations and, in some cases, imaging center
closures.  Second, in recent years, we have observed greater participation in high deductible health plans by patients.
As these high deductibles reset in January for most of these patients, we have observed that patients utilize medical services
less during the first quarter, when securing medical care will result in significant out-of-pocket expenditures.”

Item 7. Management’s Discussion
and Analysis of Financial Condition and Results of Operations, page 35

 3. Please disclose in the Overview section the total diagnostic imaging services performed for
each year the consolidated statements of operations are presented.

We propose to include a
disclosure in future filings, substantially as follows (with appropriate changes for the applicable periods presented):

“The total number
of diagnostic imaging services performed for each of the years ended December 31, 2012, 2011 and 2010, were 4,142,267,
3,740,443 and 3,315,019, respectively.”

 4. Please tell us whether you have off-balance sheet arrangements pursuant to Item 303(a)(4) of
Regulation S-K. If so, present off-balance sheet arrangements in a separately-captioned section in future filings.

We advise the Staff that
we do not have any off-balance sheet arrangements pursuant to Item 303(a)(4) of Regulation S-K.

 5. We note other operating expenses increased significantly (over 15%) during the year ended December
31, 2012 and the quarter ended March 31, 2013. Please provide a draft disclosure to be included in future filing that describes
the cause(s) of this change. Please refer to Regulation S-K 303(a)(3). Alternatively, explain why you believe such disclosure is
not necessary.

We advise the Staff that
the increase referred to in the comment above is related to the additional expenses associated with centers added from our acquisition
of Lenox Hill.

U.S. Securities and Exchange Commission

Division of Corporation Finance

October 11, 2013

Page 3

We propose to include a
disclosure in future filings with respect to Other Operating Expenses, substantially as follows (with appropriate changes for the
applicable periods presented):

“Other operating expenses,
including billing fees, office supplies, repairs and maintenance, insurance, business tax and license,
outside services, utilities, marketing, travel and other expenses increased $6.3 million, or 17.9%, to $41.4 million for the three
months ended March 31, 2013 compared to $35.1 million for the three months ended March 31, 2012.

Other operating expenses, including
only those centers which were in operation throughout the first quarters of both 2013 and 2012, decreased $736,000, or 2.1%. This
2.1% decrease is in line with our decrease in procedure volumes at these centers. This comparison excludes expenses from centers
that were acquired or divested subsequent to January 1, 2012. For the three months ended March 31, 2013, other operating expenses
from centers that were acquired subsequent to January 1, 2012 and excluded from the above comparison were approximately $7.0 million.”

Item 8. Financial Statements and Supplementary
Data, page 50

Consolidated Statements of Operations,
page 52

 6. It appears that the caption “Cost of operations” excludes depreciation and amortization
for property and equipment directly attributed to the generation of revenue. If so, revise your presentation to comply with SAB
11:B, as applicable, by disclosing parenthetically that depreciation and amortization are excluded from the caption “Cost
of operations.”

We confirm that in future
filings, as appropriate, we will revise our presentation to reflect “Cost of operations” as “Cost of operations,
excluding depreciation and amortization”.

Note 1 – Nature of Business, page
57

 7. Please tell us how your VIE disclosures comply with the requirement to present assets and liabilities
of the VIE on the face of your consolidated balance sheets pursuant to ASC 810-10-45-25.

We determined under ASC
810-10-45-25 that it is not necessary to present assets and liabilities of our VIE on the face of the consolidated balance sheets
for the following reasons:

 1. None of our VIE’s assets are pledged, or restricted solely for use in settlement of obligations
of the VIE; and

U.S. Securities and Exchange Commission

Division of Corporation Finance

October 11, 2013

Page 4

 2. Our VIE has no outstanding obligations of its own.

Note 2 – Summary of Significant
Accounting Policies, page 58

Reclassification, page 58

 8. Please tell us why the reclassification was appropriate pursuant to ASC 954-605-45-5(b). We
note that it is your policy “to attempt to collect amounts due from patients…at the time of service.”

The reclassification referenced in the comment
above was appropriate given the guidance in ASC 954-605-45-4, which states:

“Some health care entities may perform services for patients for which the ultimate collection of all or a portion of the amounts billed or billable cannot be determined at the time services are rendered. For example, some health care entities have a policy of providing services to patients and recording patient service revenue regardless of their ability to pay and, in some cases (for example, hospital emergency departments), are required by law to treat emergency conditions regardless of a patient’s ability to pay. As a result, those health care entities might record revenue along with a relatively high bad-debt provision in the period of service. A health care entity that recognizes significant amounts of patient service revenue at the time the services are rendered even though it does not assess the patient’s ability to pay shall present all of the following as separate line items on the face of the statement of operations:

1.	Patient service revenue (net of contractual allowances and discounts)

2.	The provision for bad debts (the amount related to patient service revenue and included as a deduction from patient service revenue)

3.	The resulting net patient service revenue less the provision for bad debts.”

As mentioned in the guidance
above, a health care entity should present net patient revenue net of the provision for bad debts if it recognizes significant
amounts of patient service revenue at the time the services are rendered even though it does not assess the patient’s ability
to pay. Although we attempt to collect deductibles and co-payments due from patients with insurance at the time of service, this
attempt to collect at the time of service is not an assessment of the patient’s ability to pay nor are revenues recognized
based on an assessment of the patient’s ability to pay. As indicated in Note 2 of our financial statements included in our
Form 10-K for the year ended December 31, 2012, “A significant portion of our provision for bad debt relates to co-payments
and deductibles owed to us by patients with insurance.” The reason that a significant portion of our provision for bad debt
relates to co-payments and deductibles is that the revenue for such co-payments and deductibles is recognized absent an assessment
of the patient’s ability to pay. As such, the guidance in ASC 954-605-45-4 is applicable to RadNet. We are not subject to
the guidance provided for in ASC 954-605-45-5(b) as it is applicable if “the entity only recognizes revenue to the extent
it expects to collect that amount”, which is not the manner in which we recognize revenue.

U.S. Securities and Exchange Commission

Division of Corporation Finance

October 11, 2013

Page 5

Revenues, page 59

 9. Please separately present managed care capitation revenues pursuant to ASC-954-605-45-3. We
note that you received 13% of your payments from capitation arrangements in 2012. Please comply with this comment in future filings
and confirm your compliance with us.

We confirm that in future
filings we will separately present managed care capitation revenues pursuant to ASC 954-605-45-3.

Deferred Financing Costs, page 60

 10. Please tell us why you are not amortizing the deferred financing costs under the effective interest
method.

We advise the Staff that
we are not amortizing deferred financing costs under the effective interest method because we have determined that the difference
in amortization between an amount calculated under the effective interest rate method and under the straight line method is immaterial
(less than 0.1% of total consolidated quarterly interest expense for all periods presented). Accordingly, we have determined that
the straight line method, which we currently apply, approximates the effective interest rate method.

We propose to include in
future filings the following revised critical accounting policy:

“DEFERRED FINANCING COSTS - Costs of financing
are deferred and amortized on a straight-line basis over the life of the associated loan, which approximates the effective interest
rate method.”

Note 4 – Facility Acquisitions,
page 66

 11. Please tell us how you considered ASC 805-20-25-12 and 13 in concluding that favorable lease
and customer-related intangible assets were not required to be recognized for Pueblo Radiology acquisition.

At the closing of the Pueblo
Radiology acquisition, we determined that all rents associated with the operating lease assumed as part of our purchase of Pueblo
Radiology were at current market value. Accordingly, no amount for favorable lease contracts was recorded.

U.S. Securities and Exchange Commission

Division of Corporation Finance

October 11, 2013

Page 6

Further, no intangible
assets such as those described in ASC 805-20-25-13 were identified in the Pueblo Radiology acquisition as the lease did not provide
entry into a market or other future economic benefits that qualify as identifiable intangible assets. In addition, we evaluated
whether there were other identifiable intangible assets acquired and concluded there were none (see response to comment #12 below
for more information).

Note 5 – Goodwill and Other Intangible
Assets, page 70

 12. Based on Note 4, it appears that since January 1, 2010 you recognized customer-related intangible
assets for only the Imaging On Call, LLC acquisition. Please tell us how you considered ASC 805-20-25-10 and 805-20-55-23 through
28 in concluding that customer-related intangible assets were not required to be recognized apart from goodwill for acquisitions
other than Imaging On Call, LLC.

Imaging On Call, LLC is
a teleradiology business. Its revenues are driven by contracts with customers including hospitals, clinics, and imaging centers
which we acquired. As a result, Imaging On Call’s customers were recognized as a separable and identifiable intangible asset.

Our acquisitions since
January 1, 2010, other than Imaging On Call, LLC, have been limited to diagnostic imaging companies. Typically, diagnostic imaging
companies have customer-related intangible assets in the form of contracts with physician groups. However, when RadNet acquires
diagnostic imaging companies in California, any existing contracts with physician groups are cancelled and physicians become employees
of RadNet’s Beverly Radiology Medical Group (BRMG). For acquisitions of diagnostic imaging companies outside California,
any existing contracts with physician groups are cancelled and RadNet enters into new contracts with new local physicians. In both
cases, there are no acquired customer-related intangible assets to be recognized apart from goodwill.  RadNet believes that
its cancelling of existing contracts with physician groups is consistent with a market participant’s treatment of such contracts.

Note 8 – Notes Payable, Line of
Credit and Capital Leases, page 71

 13. We note you refinanced your credit facility in October 2012 and April 2013. Please tell us how
you considered ASC 470-50, Modifications and Extinguishment, for these transactions and provide us with your analysis to determine
if the transactions were a modification or extinguishment.

We determined that the
refinancing of our credit facility in October 2012 and then again in April 2013 were each modifications of our existing credit
facility under ASC 470-50 and were accounted for as such.  We made this determination as follows:

U.S. Securities and Exchange Commission

Division of Corporation Finance

October 11, 2013

Page 7

Background:

In April 2010, RadNet entered
into a Credit and Guaranty Agreement (“2010 Credit Facility”) whereby Radnet Management Inc. obtained a $285.0 million,
six year term loan and a $100.0 million, five year revolving credit facility.  The revolving credit facility was increased
by $21.25 million in November 2011 for a total revolving credit facility of $121.25 million. For the purposes of our analysis,
this 2010 Credit Facility is considered the “Original Debt Instrument”.

In October 2012, RadNet
completed a refinancing of the 2010 Credit Facility by entering into a new Credit and Guaranty Agreement providing for a $350 million,
six year term loan and a $101.25 million revolving five year credit facility.  For the purposes of our analysis, this transaction
is the “October 2012 Refinance”.

In April 2013, RadNet refinanced
the October 2012 term loan component of its credit facility by entering into a $388.3 million term loan payable over the same time
frame as the October 2012 term loan.  No adjustment was made to the revolving credit facility in April 2013.  For the
purpose of our analysis, this transaction is the “April 2013 Refinance”.

The Original Debt Instrument
as well as the new term loans executed in October 2012 and April 2013 were loan participations with Barclays as the lead lender.
Accordingly, we applied the guidance in ASC 470-50 on a single lender basis (Barclays to Barclays).

October 2012 Refin