SecProbe.io

September 16, 2025
Peter Colis
Chief Executive Officer
Ethos Technologies Inc.
90 New Montgomery Street, Suite 1500
San Francisco, CA 94105
Re:Ethos Technologies Inc.
Amendment No. 2 to
Draft Registration Statement on Form S-1
Submitted August 27, 2025
CIK No. 0001788451
Dear Peter Colis:
            We have reviewed your amended draft registration statement and have the following
comments.
            Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement and non-public draft submissions on EDGAR. 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 the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in
our August 20, 2025 letter.
Amendment No. 2 to Draft Registration Statement on Form S-1
Management’s Discussion and Analysis
Results of Operations
Revenue, page 94
1.Please revise your filing to ensure that the amounts included in your tabular
presentation of total revenues for DTC channel revenues and third-party channel
revenues total the amounts reported for total revenues for both the six-months ended
June 30, 2025 and 2024.

September 16, 2025
Page 2
Business
The Ethos Platform, page 115
2.We note your response to prior comment 4 and the statement that you receive medical
records and prescription data from your counterparties. With a view to clarifying
disclosure to the extent material to an understanding of your business and the risk
factor on page 29, please advise us of the flow of such information used by you. For
example, clarify if consumers consent to the information released by third parties
when they seek insurance through your platform.
Notes to Consolidated Financial Statements
Accounts Receivable, Net, page F-18
3.Please refer to prior comment 9. Please revise your filing to also provide a rollforward
of your accounts receivable activities for the six-months ended June 30, 2025.
            Please contact John Spitz at 202-551-3484 or Michael Henderson at 323-965-3807 if
you have questions regarding comments on the financial statements and related
matters. Please contact Aisha Adegbuyi at 202-551-8754 or James Lopez at 202-551-3536
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:Jon Avina, Esq.