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    10250
                                            Constellation Blvd.

                                            19th Floor

                                            Los Angeles, CA 90067

                                            310.553.3000 TEL

                                            310.556.2920 FAX

                                                                     July
                                            31, 2024

    Marc
                                            A. Indeglia

    Direct
    Dial

    310.282.6245

    Direct
    Fax

    310.785.3545

    Email

    mindeglia@glaserweil.com

    Katherine
                                            Bagley, Esq.

    Robert
    Augustin, Esq.

    Securities
    and Exchange Commission

    100
    F Street, N.E.

    Washington,
    DC 20549

  Re:
  INVO Bioscience, Inc.

  Registration Statement on Form S-3

  Filed May 21, 2024

  File No. 333-279593

Dear
Ms. Bagley and Mr. Augustin:

On
behalf of our client, INVO Bioscience, Inc., a Nevada corporation (the “Company”), set forth below is the Company’s
response to the comment of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
delivered by way of it letter dated July 18, 2024 (the “Comment Letter”) with respect to the Company’s Registration
Statement on Form S-3 filed with the Securities and Exchange Commission (the “Commission”) on May 21, 2024 (the “Registration
Statement”). For your convenience, we have included the original comment from the Comment Letter in their entirety.

Registration
Statement on Form S-3

Incorporation
of Certain Documents by Reference, page 2

 1. We
                                            have read your response to prior comment 1 and reissue in part. Please provide the objective
                                            evidence that you used to determine the purported incremental borrowing rates cited in your
                                            response. In this regard, please note that these estimates should be based on relevant objective
                                            and observable data and also any market-based data that is comparable to the registrant’s
                                            facts and circumstances. Your analysis should provide all calculations and clearly correlate
                                            your conclusions with the actual borrowing rates reported in the Registrant’s financial
                                            statements as well as the Registrant’s operating performance and liquidity at inception
                                            of the leases. In your response, please also clarify how you reasonably concluded that the
                                            Registrant’s incremental borrowing rates could possibly range as low as 2.54% given
                                            the Registrant’s consistent operating losses and cash flow deficits and the fact that
                                            the Registrant’s actual borrowing rates range from 10% to 100%. Also, if you used an
                                            assumption about the spread in market rates between collateralized and uncollateralized debt
                                            then please provide that data to us. We may have further comment.

Response:
In determining its incremental borrowing rates for the leases, the Company reviewed the Survey of Terms of Business Lending from the
Small Business Credit Survey collected by the Federal Reserve Bank of Kansas City (located at https://www.nav.com/small-business-loans/commercial-interest-rates/)
and the historical interest rates for the SBA 504 Loan Program as published by the Nebraska Business Development Center (located at https://nedcoloans.org/historical-rates-year/).
Due to its financial condition (including, without limitation, its operating losses and cash flow deficits) at each of the relevant measurement
periods, the Company elected to use the interest rates published by the Federal Reserve Bank of Kansas City as its incremental borrowing
rates, which were consistently higher than those of the SBA 504 Loan Program. Although the Company has had past borrowings, these borrowings
did not occur at or near the commencement date of each lease, and the terms of the borrowings were not of similar terms to the leases
in question.

    Katherine Bagley, Esq.

Robert Augustin, Esq.

Securities and Exchange Commission

July 31, 2024

Page 2

In
further consideration of the Staff’s partial re-issuance of its comment, the Company has engaged Scalar, a leading independent
valuation firm, to provide an opinion regarding the Company’s incremental borrowing rates for each lease in question. Scalar determined
that the most appropriate methodology for determining the incremental borrowing rates was to develop a synthetic credit rating for the
Company as of the commencement date of each lease, since, as stated above, the Company’s past borrowings do not coincide in commencement
date or term with any of the leases, and since the Company does not have an established credit rating.

To
do this, Scalar performed an analysis using a random forest algorithm to compare various financial metrics of the Company against other
public companies. (These metrics are set forth in the table attached hereto as Exhibit A.) The source data for this comparison
included all publicly credit rated companies on major exchanges. The model then compares the Company’s financial metrics as of
the lease commencement date to the financial metrics of the data for the publicly credit rated companies to determine the appropriate
credit rating for the Company. Based on the foregoing analysis, Scalar determined that the Company’s synthetic credit rating for
each of the leases was CCC+.

Since
an incremental borrowing rate for a lease would represent a collateralized rate, Scalar adjusted the synthetic rating upward by one notch
(CCC+ to B-) to reflect the reduced risk. Lastly, Scalar took the adjusted synthetic rating and the various terms of the leases and selected
the incremental borrowing rate based on the commencement date, duration of the lease, and a corresponding corporate yield curve. Since
S&P data does not provide + or – yield curve ratings, Scalar considered both the B and CCC yield curve and applied a 75% weighting
to the B rating as B- is closer to a B than a CCC rating.

    Katherine Bagley, Esq.

Robert Augustin, Esq.

Securities and Exchange Commission

July 31, 2024

Page 3

Upon
further review and analysis, the Company has determined that the following are the proper incremental borrowing rates for each lease:

    Lease
    Incremental
    Borrowing Rate

    Commercial Lease Agreement dated
    May 1, 2019 between the Company and PJ LLC
    8.80%

    Lease Agreement dated March 2021 with Trustmark
    National Bank
    7.45%

    Sublease Agreement dated June 29, 2021 between
    Assure Fertility Partners of Atlanta II and Bloom INVO LLC
    6.76%

    Lease Agreement dated May 23, 2022 between
    4602 North Armenia Ave, LLC and INVO Centers, LLC
    10.51%

    Lease Agreement dated July 1, 2023 between
    Taylyn Holdings, LL and Wood Violet Fertility, LLC
    10.28%

Scalar’s
final opinion is attached hereto as Exhibit B.

Had
the Company used the foregoing incremental borrowing rates to determine its lease liabilities, the Company’s lease liabilities
would have been $4,239,252 as of December 31, 2023 and $2,799,442 as of March 31, 2024 (as opposed to $5,919,644 as of
December 31, 2023 and $3,490,579 as of March 31, 2024). This reflects an impact to lease liabilities of $(1,680,392) as of December 31,
2023 and an impact of $(691,137) as of March 31, 2024. Correspondingly, the Company’s lease right of use assets would have been
$4,060,537 as of December 31, 2023 and $2,678,092 as of March 31, 2024 (as opposed to $5,740,929 as of December 31, 2023 and $3,369,229
as of March 31, 2024). This reflects an impact to right of use assets of $(1,680,392) as of December 31, 2023 and an impact of $(691,137)
as of March 31, 2024.1 For all periods, the differences are less than 10% of the respective financial statement category.
Further, there would be no impact on net loss, earnings per share, or net equity, either for the year ending December 31, 2023 or the
three months ending March 31, 2024.

1
The Company notes that the material decrease in the amount of lease right of use assets and lease liability from December 31, 2023
and March 31, 2024 results from the Company’s termination of the Lease Agreement dated May 23, 2022 between 4602 North Armenia
Ave, LLC and INVO Centers, LLC.

    Katherine Bagley, Esq.

Robert Augustin, Esq.

Securities and Exchange Commission

July 31, 2024

Page 4

The
Company again assessed the materiality of the error in incremental borrowing rates by considering both the quantitative and qualitative
considerations outlined in the materiality guidance set forth in SEC Staff Accounting Bulletin Topic 1.M and 1.N. The Company has again
determined that the error can be corrected as an out-of-period adjustment because it is immaterial to both the current and prior period(s).
Quantitively, as noted above, the impact was limited to assets and liabilities and was less than 10% for each financial statement category
for each period. Moreover, and more significantly, there was no quantitative impact on revenue, net loss, earnings per share, or net
equity.

Qualitatively,
the error has resulted in no change to the business plan or operations of the Company. The error has not and will not result in any impact
to loan covenants, contractual agreements, regulatory requirements, or management compensation. As stated above, neither the Company’s
net loss nor its earnings (loss) per share is materially altered as a result of the error; rather, the error results in a gross down
of assets and liabilities by a very similar amount. It is the Company’s position that that, qualitatively, a reasonable investor
would not consider these particular assets and liabilities important in making an investment decision regarding the Company.

The
Company intends to amend its Form 10-K for the year ending December 31, 2023 to update the disclosures related to the incremental borrowing
rate and the disclosures required by ASC 842-20-50-4 by revising the first paragraph of Footnote 9 to the financial statements to read
as follows:

The
Company has various operating lease agreements in place for its office and joint ventures. Per FASB’s ASU 2016-02, Leases Topic
842 (“ASU 2016-02”), effective January 1, 2019, the Company is required to report a right-of-use asset and corresponding
liability to report the present value of the total lease payments, with appropriate interest calculation. The rate implicit in the lease
was not readily determinable. Historically, the Company historically utilized the applicable federal rate as of the commencement of the
lease, however, the Company has determined that utilization of the applicable federal rate was not its comparable incremental borrowing
rate. The Company has since calculated the incremental borrowing rate for each lease by developing a synthetic credit rating for the
Company as of the commencement date of each lease, adjusting the synthetic credit rating to reflect the collateralized nature of the
incremental borrowing rate, and based on the adjusted synthetic rating and the various terms of the leases, selected the incremental
borrowing rate based on the commencement date, duration of the lease, and a corresponding weight-adjusted corporate yield curve. The
Company then completed a sensitivity analysis on all of its current leases and determined there was no material difference between using
the applicable federal rate and the applicable incremental borrowing rate. Lease renewal options included in any lease are considered
in the lease term if it is reasonably certain the Company will exercise the option to renew. The Company’s operating lease agreements
do not contain any material restrictive covenants.

    Katherine Bagley, Esq.

Robert Augustin, Esq.

Securities and Exchange Commission

July 31, 2024

Page 5

The
Company intends to further amend its Form 10-K for the year ending December 31, 2023 to update the disclosures related to the incremental
borrowing rate and the disclosures required by ASC 842-20-50-4 by revising the fourth paragraph of Footnote 9 to the financial statements
to read as follows:

For
the year ended December 31, 2023, the weighted average remaining lease term for operating leases was 150 months. For the year ended December
31, 2023, the weighted average discount rate for operating leases was 9.7%. The Company paid approximately $0.3 million in cash for operating
lease amounts included in the measurement of lease liabilities for the year ended December 31, 2023. The Company did not have any finance
leases as of December 31, 2023.

The
Company intends to amend its Form 10-Q for the period ending March 31, 2024 as follows to update the disclosures related to the incremental
borrowing rate and the disclosures required by ASC 842-20-50-4 by revising the first paragraph of Footnote 9 to the financial statements
to read as follows:

The
Company has various operating lease agreements in place for its office and joint ventures. Per FASB’s ASU 2016-02, Leases Topic
842 (“ASU 2016-02”), effective January 1, 2019, the Company is required to report a right-of-use asset and corresponding
liability to report the present value of the total lease payments, with appropriate interest calculation. The rate implicit in the lease
was not readily determinable. Historically, the Company historically utilized the applicable federal rate as of the commencement of the
lease, however, the Company has determined that utilization of the applicable federal rate was not its comparable incremental borrowing
rate. The Company has since calculated the incremental borrowing rate for each lease by developing a synthetic credit rating for the
Company as of the commencement date of each lease, adjusting the synthetic credit rating to reflect the collateralized nature of the
incremental borrowing rate, and based on the adjusted synthetic rating and the various terms of the leases, selected the incremental
borrowing rate based on the commencement date, duration of the lease, and a corresponding weight-adjusted corporate yield curve. The
Company then completed a sensitivity analysis on all of its current leases and determined there was no material difference between using
the applicable federal rate and the applicable incremental borrowing rate. Lease renewal options included in any lease are considered
in the lease term if it is reasonably certain the Company will exercise the option to renew. The Company’s operating lease agreements
do not contain any material restrictive covenants.

The
Company intends to further amend its Form 10-Q for the period ending March 31, 2024 as follows to update the disclosures related to the
incremental borrowing rate and the disclosures required by ASC 842-20-50-4 by revising the fourth paragraph of Footnote 9 to the financial
statements to read as follows:

For
the three months ended March 31, 2024, the weighted average remaining lease term for operating leases was 105 months. For the three months
ended March 31, 2024, the weighted average discount rate for operating leases was 9.0%. The Company paid approximately $0.3 million in
cash for operating lease amounts included in the measurement of lease liabilities for the three months ended March 31, 2024. The Company
did not have any finance leases as of March 31, 2024.

    Katherine Bagley, Esq.

Robert Augustin, Esq.

Securities and Exchange Commission

July 31, 2024

Page 6

On
behalf of the Company, please be advised that the Company has endeavored to