SecProbe.io

December 2 4, 2012

Via E -mail
Mark McLaughlin
President
Immudyne, Inc.
50 Spring Meadow Rd.
Mount Kisco, NY 10549

Re: Immudyne , Inc.
Registration Statement on Form S -1/A
Filed December 5, 2012
  File No. 333 -184487

Dear Mr. M cLaughlin :

We have reviewed your registration statement and have the following comments.
In some of our comments, we may ask you to provide us with information so we may
better understand your disclos ure.

Please respond to this letter by amending your registration statement and
providing the requested information.   If you do not believe our comments apply 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 these comments, we may have additional
comments.

Mr. Mark McLaughlin
Immudyne , Inc.
December 2 4, 2012
Page 2

 FORM S -1/A

Risk Factors, page 4
“We derive a substantial part of our sales from one major customer..” page 6

1. We note your response to our prior comment number 8 in which we asked you to
disclose here, as you had done previously in the Business section, the name of
your major customer.  Please name the major customer here and in the Business
section or provide us with an analysis supporting your determination that the
name of this customer is not material to invest ors.  Please note that if you wish the
Staff to consid er any information in your response letter on a confidential basis,
you should  provide such information in accordance with the requirements and
procedures set forth under Rule 83  of the Commission’s Rules of Practice .  Please
see http://www.sec.gov/foia/co nftreat.htm.

Our Business, page 26

2. Please identify which research facility, institution or doctor conducted the side by
side comparison analysis between your product and other beta glucan products of
your competitors. Please discuss how many other produc ts your product was
compared against and what were the specific factors or findings that led you to
conclude that your yeast beta glucan is a superior yeast beta glucan.

3. Please expand your disclosure regarding the healthcare professionals that have
taken  an interest in your immune -support products.  Clarify the type of healthcare
professionals (i.e. licensed physicians, alternative medicine practitioners,
scientists, researchers, etc.) and whether such expressions of interest have resulted
in research stu dies or increased use or recommendation of your product.
4. Please name the medical institutions and medical doctors who conduct testing,
analysis and beta work for your specific products on your behalf.  Please describe
how such work is funded and whether yo u have formal clinical development or
research agreements with such institutions and/or physicians.

Certain Relationships and Related Party Transactions, page 36
5. Please clarify whether Akin, Gump also defers without interest payments due
under the royalt y agreement.

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes the information the Securities
Act of 193 3 and all applicable Securities  Act rules require.   Since the company and its
management are in possession of all facts relating to a company’s disclosur e, they are
responsible for the accuracy and adequacy of the disclosures they have made.

Mr. Mark McLaughlin
Immudyne , Inc.
December 2 4, 2012
Page 3

Notwithstanding our comments, in the event you request acceleration of the
effective date of the pending regist ration statement please provide  a written statement
from the company acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commission from taking any
action with respect to the filing;

 the action of the Commi ssion or the staff, acting pursuant to delegated authority,
in declaring the filing effective, does not relieve the company from its full
responsibility for the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff c omments and the declaration of effectiveness
as a defense in any proceeding initiated by the Commission or any person under
the federal securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will
consider a written request for acceleration of the effective date of the registration
statement as confirmation of the fact that those requesting acceleration are aware of their
respective responsibilities under the Securities Act of 1933 and the Securitie s Exchange
Act of 1934 as they relate to the proposed public offering of the securities specified in the
above registration statement.  Please allow adequate time  for us to review any
amendment prior to the requested effective date of the registration stat ement.

You may contact Jim Peklenk  at (202) 551 -3661 or Donald Abbott  at (202) 551 -
3608 if you have questions regarding comments on the financial statements and related
matters.  Please contact Nandini Acharya  at (202) 551 -3495,  Dan Greenspan, Legal
Branch Chief at (202) 551 -3623  or me at (202) 551 -3715 with any other questions.

Sincerely,

 /s/ Daniel  Greenspan for

 Jeffrey  P. Riedler
Assistant Director

 Via E -mail
cc: Gerald A. Adler, Esq.
 Mitul Patel, Esq.
Newman & Morrison LLP
44 Wall Street, 20th Floor
New York, NY   10005