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    100
                                         Park Avenue, Suite 1500

        New York,
        NY 10017

        Tel 212.878.7900
        Fax 212.692.0940

        www.foxrothschild.com

    Alison
                                      Newman

        Direct Dial: 212-878-7997

        Email Address: ANewman@Foxrothschild.com

April 4, 2014

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

 Attention: Mark P. Shuman

Ivan Griswold

Laura Veator

Stephen Krikorian

 Re: Medical Transcription Billing, Corp.

  Registration Statement on Form S-1

  Filed on December 20, 2013

  File No. 333-192989

Ladies and Gentlemen:

On behalf of our
client, Medical Transcription Billing, Corp. (“MTBC” or the “Company”), we are responding
to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
contained in its letter dated January 9, 2014 (the “Comment Letter”), relating to the above referenced Registration
Statement on Form S-1 (the “Registration Statement”). In response to the comments set forth in the Comment Letter,
MTBC has revised the Registration Statement and is filing Amendment No. 1 to the Registration Statement with this response letter.
We are also providing by overnight mail for the Staff’s reference a copy of Amendment No. 1 to the Registration Statement
marked to show all changes from the Registration Statement filed on December 20, 2013.

In this letter,
we have recited the comments from the Staff in italicized, bold type and have followed each comment with the Company’s response.
Except as otherwise specifically indicated, page references herein correspond to the page of the revised draft of the Registration
Statement, as applicable.

U.S. Securities and Exchange Commission

April 4, 2014

Page 2

Unaudited Pro Forma Condensed
Combined Financial Information, page 37

1.
	We note your response to prior comment 9. Please revise your disclosure to describe the factors that you considered
in determining that it is more likely than not that your tax benefit from your pro forma loss will be realized against taxable
income generated in future years.

The Company advises the Staff that it has
revised the disclosure on pages 46 and 47 as requested by the Staff.

Management’s Discussion and Analysis
of Financial Condition and Results of Operations

Case Study: Metro Medical Acquisition,
page 50

2.
	We note your response to prior comment 11. Since the profit margin excludes indirect expenses, the profit margin appears
to be a Non-GAAP measure. As such, a non-GAAP measure is subject to all of the provisions of Regulation G and Item 10(e) of Regulation
S-K. We refer you to Compliance & Disclosure Interpretations: Non-GAAP Financial Measures Question 104.05. Please revise your
presentation to provide this information. Alternatively, please exclude the measure of profit margin from your presentation. Further,
please clarify your disclosure to describe the expenses that are excluded from your presentation and the reasons why. Lastly, use
of the term “profit margin” suggests that you are generating profits. Please revise throughout the document, to reference
“gross margin” instead.

The Company advises the Staff that it has
included the case study to provide investors with meaningful information demonstrating the impact of changes in revenue and controllable
expenses effected by the Company in the months following an acquisition, using the acquisition of Metro Medical as an example.
The Company included all directly identifiable costs associated with the corresponding revenue, including compensation expense
for former Metro Medical employees retained following the acquisition, compensation expense of the Company’s employees in
Pakistan who exclusively service former Metro Medical customers, as well as general and administrative expenses such as rent, communication,
and postage expense associated with Metro Medical’s former offices in New York City.

The Company excluded from directly identifiable
expenses any allocation of corporate overhead, amortization of intangibles, interest or taxes, because the Company’s objective
is to focus on changes in operational performance. The intention is to provide a consistent metric showing the trend over successive
months, not to compare the results of an acquisition with the profitability of a stand-alone business. The Company feels that the
trend in contribution margin is a useful predictor of similar trends for future acquisitions.

U.S. Securities and Exchange Commission

April 4, 2014

Page 3

The Company further advises the Staff that
it has revised the presentation to refer to “contribution margin” rather than “profit margin.”

Quantitative and Qualitative Disclosures
about Market Risk, page 64

3.
	We note your revised disclosure on page 71 that your actual payments to your Pakistani subsidiary for services are in
an amount to cover actual costs incurred by the subsidiary and the excess amount owed by you but not paid is treated as a dividend.
Accordingly, you record a tax liability in your financial statements to cover U.S. taxes on that dividend. However, we note your
disclosure on page F-22 that as a result of your plans to repatriate earnings in Pakistan to the United States your earnings are
fully provided for at the full U.S. federal rate. Please clarify your disclosures to indicate whether you record a tax liability
on the entire earnings generated by your Pakistan subsidiary or only the excess amount owed by you but not paid to the subsidiary.

The Company advises the Staff that it has
clarified the disclosure on page 71. The Company records a tax liability on all earnings and profits generated by its Pakistani
subsidiary at the federal tax rate. The Company records a current tax liability related to the dividend, and a deferred tax liability
for the cumulative earnings and profit generated by its Pakistani subsidiary, as reduced by the amount treated as a dividend.

Acquisitions

Indemnification and Escrow, page
89

4.
	Please expand your disclosure to state clearly who will exercise voting and investment power over the shares to be issued
to the Target Sellers while they are escrowed.

The Company advises the Staff that it has
revised the disclosure on page 93 as requested.

Executive Compensation, page 102

5.
	Please expand the summary compensation table to include the required compensation information concerning applicable
executive officers for 2013, your most recent fiscal year. Similarly update the other information in this section of the filing
that is provided at December 31, 2012 and for the year then ended.

U.S. Securities and Exchange Commission

April 4, 2014

Page 4

The Company advises the Staff that it has
revised the disclosure to include all required compensation information for applicable executive officers for 2013 and has updated
other information in the Executive Compensation section that is provided at December 31, 2012 and for the year then ended.

Certain Relationships and Related
Party Transactions, page 108

6.
	Also, update throughout this section to provide information responsive to Item 404 of Regulation S-K with respect to
applicable transactions that occurred during the most recent year, 2013, or which are ongoing thereafter.

The Company advises the Staff that it has
revised the disclosure to include all applicable transactions that occurred during 2013.

Where You Can Find More Information,
page 127

7.
	Please delete the phrase “in all respects” from the third sentence of this paragraph.

The Company advises the Staff that it has
deleted the phrase as requested.

Sincerely,

/s/ Alison Newman

 cc: Mahmud Haq, Medical Transcription Billing, Corp.

  Bill Korn, Medical Transcription Billing, Corp.

  Steven Snyder, Medical Transcription Billing, Corp.

  Mitchell Nussbaum, Loeb & Loeb LLP