SecProbe.io

March 19, 2025
Matthew Mills
Chief Executive Officer
Med-X, Inc.
8236 Remmet Avenue
Canoga Park, CA 91304
Re:Med-X, Inc.
Amendment No. 4 to Offering Statement on Form 1-A
Filed March 10, 2025
File No. 024-12516
Dear Matthew Mills:
            We have reviewed your amended offering statement and have the following
comments.
            Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe a comment applies 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 offering statement and the information you
provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our February 21, 2025 letter.
Amendment No. 4 to Offering Statement on Form 1-A
Cover Page
1.We note your response to prior comment 1, and we reissue the comment in part.
Please tell us how your disclosure regarding the broker commissions of 4.5%
reconciles to the 6.5% cash fees from all proceeds specified on Schedule A of your
agreement with DealMaker Securities LLC filed as Exhibit 6.10 or revise your
disclosure as appropriate.
Summary
Recent Developments, page 7
We note your response to prior comment 2, and we reissue in part prior comment 3 in
our letter dated January 10, 2025. As previously requested, please provide us with 2.

March 19, 2025
Page 2
your legal analysis as to whether your offering made in reliance on Regulation
Crowdfunding and your separate private placement, each as referenced in your
offering statement, may be subject to integration with the offering covered by this
offering statement. In your response, please address the "commencement" of this
offering, and the impact of any such commencement, on the potential integration of
these offerings, notwithstanding your statement that you intend to close your other
offerings prior to "launch" of this offering. Refer to Securities Act Rule 152, including
specifically Rule 152(c)(3), which refers to "the public filing of a Form 1-A offering
statement" as a factor in determining when an offering of securities will be deemed to
be commenced.
3.We note your added disclosure that, on February 11, 2025, you filed a Regulation D
offering for $2,000,000 that is ongoing. However, it appears from the related Notice
of Exempt Offering of Securities on Form D, as amended, that the total offering
amount is $2,300,000. Please revise your disclosure accordingly.
Signatures, page 69
4.We note that you replaced the "Principal Financial Officer" designation from the
capacity in which Ronald J. Tchorzewski signed the offering statement with the
"Principal Accounting Officer" designation. Please revise the signature page to also
identify who is signing the offering statement as your principal financial officer. Refer
to Instruction 1 to "Signatures" in Form 1-A.
            Please contact Franklin Wyman at 202-551-3660 or Lynn Dicker at 202-551-3616 if
you have questions regarding comments on the financial statements and related
matters. Please contact Jessica Dickerson at 202-551-8013 or Tim Buchmiller at 202-551-
3635 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Jesse Blue, Esq.