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    One Financial Center

    Boston, MA 02111

    617 542 6000

    mintz.com

October 4, 2024

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Officer of Mergers & Acquisitions

100 F Street, N.E. Washington, D.C. 20549

Attention: Brian Soares and David Plattner

 Re: PSYCHEMEDICS CORP

Schedule 13E-3 filed September 3, 2024

File No. 005-39145 (the “Schedule 13E-3”)

Preliminary Proxy Statement on Schedule 14A filed September 3, 2024

File No. 001-13738 (the “Preliminary Proxy Statement”)

Ladies and Gentlemen:

We are submitting this letter on behalf of Psychemedics Corporation (the
“Company”) in response to the comments from the staff (the “Staff”) of the U.S. Securities and Exchange
Commission (the “Commission”) received by letter dated September 26, 2024 (the “Comment Letter”)
from the Division of Corporation Finance, Office of Mergers & Acquisitions, to Brian Hullinger, President and Chief Executive Officer
of the Company, relating to the above-referenced Schedule 13E-3 and Preliminary Proxy Statement. In conjunction with this letter, the
Company is filing Amendment No. 1 to each of its Schedule 13E-3 and Preliminary Proxy Statement (the “Amended Schedule 13E-3”
and the “Amended Proxy Statement”, respectively) with the Commission.

For reference, we have set forth below in italics the Staff’s comments
from the Comment Letter and have keyed the Company’s responses to the numbering of the comments and the headings used in the Comment
Letter. The responses are based on information provided to Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C. by representatives of the
Company. With respect to Comments 1 and 10, the responses herein have been provided by counsel to Peter H. Kamin whose contact information
is provided at the end of this letter. Page numbers referred to in the responses reference the applicable pages of the Amended Schedule
13E-3 and Amended Proxy Statement. Capitalized terms used herein but not defined shall have the meanings ascribed to them in the Amended
Schedule 13E-3 and Amended Proxy Statement.

Preliminary Proxy Statement and Schedule 13E-3 filed September 3, 2024

General

Comment 1: In your response letter, please explain why neither
Mr. Kamin nor any of the entities affiliated with Mr. Kamin are affiliates of the Company engaged directly or indirectly in the Rule 13e-3
transaction and should not be listed as signatories to the Schedule 13E-3 signature page and included as filing persons. For guidance,
refer to Questions 101.02, 201.01, 201.05, and 201.06 of the Division of Corporation Finance’s Compliance and Disclosure Interpretations
for Going Private Transactions, Exchange Act Rule 13e-3 and Schedule 13E-3. Alternatively, please revise and provide all of the information
required by Schedule 13E-3 as to each of Mr. Kamin and the entities affiliated with Mr. Kamin individually to the extent not already provided.
We may have further comment.

Boston     Los
Angeles     New York     San Diego     San Francisco     TORONTO     Washington

MINTZ, LEVIN, COHN, FERRIS, GLOVSKY AND POPEO,
P.C.

MINTZ

October 4, 2024

Page 2

Furthermore, we note disclosure on page 5 and elsewhere throughout the
preliminary proxy statement referring to “certain entities affiliated with Mr. Kamin” as well as references to “Mr.
Kamin and entities affiliated with him.” Please revise to clarify which entities are covered by these terms, such that all entities
affiliated with Mr. Kamin that are filing persons are providing the disclosure required by Schedule 13E-3.

Response 1: The Company acknowledges the Staff’s comment
and advises the Staff that, as permitted in the Stock Purchase Agreement, Mr. Kamin has confirmed to the Company that all of the
shares of Common Stock to be purchased by Mr. Kamin and his affiliates pursuant to the Stock Purchase Agreement will be purchased by
3K Limited Partnership and, therefore, Mr. Kamin and 3K Limited Partnership have been added as filing persons and listed signatories
to the Amended Schedule 13E-3. However, the Company has been advised by Mr. Kamin that none of the Peter H. Kamin Revocable Trust
dated February 2003, the Peter H. Kamin Childrens Trust dated March 1997, the Peter H. Kamin GST Trust and the Peter H. Kamin Family
Foundation will be purchasing shares of Common Stock from the Company in the proposed transaction, and therefore, are not an
affiliates of the Company engaged, directly or indirectly, in the Rule 13e-3 transaction and as such have not been added as filing
persons and listed signatories to the Amended Schedule 13E-3.  This analysis reflects the consideration of Question 201.05 of the
Division of Corporation Finance’s Compliance and Disclosure Interpretations of Going Private Transactions, Exchange Act Rule
13e-3 and Schedule 13E-3.

In addition, in response to the Staff’s comment, the references
to “certain entities affiliated with Mr. Kamin” as well as references to “Mr. Kamin and entities affiliated with
him” in the Amended Proxy Statement have been revised to specifically identify such affiliates.

Comment 2: The information required by Items 7, 8 and 9 of Schedule
13E-3 must appear in a “Special Factors” section prominently disclosed in the front of the proxy statement, following a summary
term sheet. See Rule 13e-3(e)(1)(ii), Item 1 of Schedule 13E-3, and Item 1001 of Regulation M-A. Item 1001 of Regulation M-A requires
the summary term sheet to briefly describe in bullet point format the most material terms of the proposed transaction. Please revise your
preliminary proxy statement accordingly.

Response 2: The Company has relocated the existing sections titled
“Special Factors Relating to the Transaction” and “Summary Term Sheet” (formerly titled “Terms of the Transaction”
in the Preliminary Proxy Statement) to p. 16 and p. 2 of the Amended Proxy Statement, respectively, and made other presentation
changes to address the Staff’s comments related to the specific format requirements of Regulation M-A. Substantively, we believe
the existing disclosures provide the information required under Regulation M-A.

Comment 3: Please correct the cross references in the Schedule
13E-3 to a section of the proxy statement titled “Financial Information,” which section is not in the preliminary proxy statement.

Response 3: The Company has updated the Amended Proxy Statement
to include a section titled “Financial Information”.

Comment 4: Where an issuer elects to incorporate by reference
the information required by Item 1010(a) of Regulation M-A, all of the summarized financial information required by Item 1010(c) must
be disclosed in the document furnished to security holders. See Instruction 1 to Item 13 of Schedule 13E-3. In addition, please refer
to Telephone Interpretation I.H.7 in the July 2001 supplement to our “Manual of Publicly Available Telephone Interpretations”
for guidance on complying with a similar instruction in the context of a tender offer. Please revise the proxy statement to include the
information required by Item 1010(c) of Regulation M-A. While we note that you have provided the book value per share of your common stock
as of June 30, 2024 on pages 51 and 53 of the preliminary proxy statement, please revise the proxy statement to include the remaining
information required by Item 1010(c) of Regulation M-A.

MINTZ

October 4, 2024

Page 3

Response 4: The Company has revised the disclosure on p. 109
of the Amended Proxy Statement to include the remaining information required by Item 1010(c) of Regulation M-A.

Comment 5: Please attach a preliminary form of proxy to the preliminary
proxy statement.

Response 5: The Company has attached a preliminary form of proxy
to the Amended Proxy Statement.

Comment 6: Please advise as to why two different figures are
disclosed regarding stockholders of record (i.e., 142 holders of record as of August 27, 2024, disclosed on page 33, and 214 holders of
record as of July 12, 2024, disclosed on pages 50 and 90), what you believe accounts for such a significant change in the number, and
whether such change has had an impact on your analysis as to how to implement the stock split.

Response 6: The Company has revised all references to the
holders of record number in the Amended Proxy Statement to reflect 213 holders of record as of September 25, 2024, counted in
accordance with Rule 12g5-1 under the Securities Exchange Act of 1934, as amended. The Company advises the Staff that the holders of
record number as of August 27, 2024 disclosed on p. 33 of the Preliminary Proxy Statement was not counted in accordance with Rule
12g5-1 under the Securities Exchange Act of 1934, as amended, due to an administrative error, which caused the discrepancy.

Terms of the Transaction, page 26

Comment 7: We note the reference on page 29 to “the small
effect of the proposed transaction on the relative voting power of Continuing Stockholders” and the various references throughout
the document to the stakes of directors and executive officers decreasing by a “nominal amount.” Please reconcile such statements
with the fact that it appears that Mr. Kamin’s shareholding stake will roughly triple as a result of the proposed transaction (from
the 11.4% mark disclosed on page 21 to the 34.5% mark disclosed on page 62), and the stakes of other Continuing Stockholders will presumably
be diluted accordingly. Please also disclose more prominently the 34.5% figure.

Response 7: The Company has revised the disclosure on p. 4, p.
5, p. 6, p. 9, p. 13, p. 30, p. 34, p. 65 and p. 100 of the Amended Proxy Statement to clarify that Mr. Kamin will beneficially own
approximately 34.5% of our shares of outstanding common stock after the Transaction.

Comment 8: On page 40, we note the following disclosure: “Our
total Transaction-related expenses could be larger or smaller depending on, among other things, the number of fractional shares that will
be outstanding after the Stock Split as a result of purchases, sales and other transfers of our shares of common stock by our stockholders,
or an increase in the costs and expenses of the Transaction.” Please add to the foregoing list of factors a specific reference to
a potential deviation from the assumed 1-for-5,000 Reverse Split ratio. Please do the same on page 51.

MINTZ

October 4, 2024

Page 4

Response 8: The Company has revised the disclosure on p. 16
and p. 27 of the Amended Proxy Statement accordingly.

Purpose of and Reasons for the Transaction, page 41

Comment 9: Please reconcile the specific annual cost savings
figure of $844,788 disclosed on page 42 with the various references throughout the document to “approximately $900,000.”

Response 9: The Company has revised references to
“approximately $900,000” to “approximately $845,000” throughout the Amended Proxy Statement,
representing the annual cost savings figure rounded to the nearest thousand.

Background of the Transaction, page 43

Comment 10: Refer to the following disclosure throughout this
section indicating that:

 · as
of December 2023, Mr. Kamin had expressed an interest to finance a potential “going dark” transaction through an equity financing
of the Company;

 · during
May 2024, Mr. Kamin delivered to the Transaction Committee multiple term sheets outlining the terms of a potential financing of the Company
to fund the Company’s proposed “going dark” transaction and entered into discussions with the Transaction Committee
regarding the terms of such potential transaction, including agreeing on a purchase price per share;

 · during
June 2024, Mr. Kamin continued to discuss the terms of the potential transaction with the Transaction Committee and members thereof,
including communicating to the Transaction Committee a revised proposal for such transaction; and as of July 2024, Mr. Kamin had accepted
a revised proposal from the Transaction Committee.

Please tell us why Mr. Kamin did not file an amendment to his Schedule
13D until August 13, 2024, the day after the Stock Purchase Agreement was executed.

Response 10: Mr. Kamin has informed the Company that he did
not file an amendment to his Schedule 13D because the events in December 2023, May 2024, June 2024 and July 2024 were merely
exploratory and preliminary negotiations that could be terminated at any time.

Mr. Kamin’s Schedule 13D/A filed on August 19, 2021 stated the following:

“[Mr. Kamin] intends to review [his] investment in the
[Company] on a continuing basis … depending on various factors.” and “[Mr. Kamin] may in the future take such actions
with respect to their investment in the [Company] as [he deems] appropriate including engaging in discussions with stockholders of the
[Company] or other third parties about the [Company] and [Mr. Kamin]’s investment, including potential business combinations or
dispositions involving the [Company] or certain of its businesses, making recommendations or proposals to the [Company] concerning changes
to the capitalization, ownership structure, board structure (including board composition), potential business combinations or dispositions
involving the [Company] or certain of its businesses, or suggestions for improving the [Company]’s financial and/or operational
performance, purchasing additional shares, selling some or all of their shares … or changing [his] intention with respect to any
and all matters referred to in Item 4 of Schedule 13D.”

MINTZ

October 4, 2024

Page 5

Because the events in December 2023, May 2024, June 2024 and July
2024 were contemplated by the disclosure contained in the previously filed Schedule 13D, Mr. Kamin does not believe that the events
during December 2023, May 2024, June 2024 and July 2024 constituted a material change to the information included in Mr.
Kamin’s Schedule 13D.

In addition, Mr. Kamin does not believe that the events in December
2023, May 2024, June 2024 and July 2024 constituted a material change in the previously filed Schedule 13D, because during the
course of those activities, neither Mr. Kamin nor the Company had formed a specific plan or intention to finance a potential
“going dark” transaction. The events in December 2023, May 2024, June 2024 and July 2024 were preliminary activities
that were conducted by the Company’s management and Board of Directors (the “Board”) and Mr. Kamin in an effort to
determine whether there was a basis for a potential “going dark” transaction. The exploratory intent and
non-binding nature of the events in December 2023, May 2024, June 2024 and July 2024 were such that, during the exploratory period,
the Company had not formed any specific plans or intention to pursue a potential “going dark” transaction. During this
time, the Company’s management was operating only under the direction of the Transaction Committee, whose mandate was to
explore the viability of a possible “going dark” transaction, including developing the potential terms of such a
transaction, in order to be evaluated by the Transaction Committee for a recommendation to the full Board, in light of the totality
of the Company’s circumstances. Such a plan and intent only could be formed with the recommendation of the Transaction
Committee and the approval of the Board. On December 20, 2023, the Board held a meeting at which it discussed, among topics, the
potential “going dark” transaction by means of a reverse stock split, including whether such a transaction would be in
the best interests of the Company’s stockholders. The Board discussed the means of funding the cost of such a transaction, and
the Board weighed various options, including using the Company’s cash on hand and seeking an external financing source. During
this discussion, Mr. Kamin indicated he may be willing to fund the transaction’s costs through an equity financing of the
Company if the Company and he were able to reach an agreement on acceptable financing terms. The Board discussed the need for
appropriate corporate governance