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May 21, 2024
Jay J. Jackson
Chief Executive Officer
Abacus Life, Inc.
2101 Park Center Drive, Suite 170
Orlando, Florida 32835
Re:Abacus Life, Inc.
Registration Statement on Form S-1
Filed May 10, 2024
File No. 333-279347
Dear Jay J. Jackson:
            We have conducted a limited review of your registration statement and have the
following comments.
            Please respond to this letter by amending your registration 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 registration statement and the information you
provide in response to this letter, we may have additional comments.
Registration Statement on Form S-1
Business
Proprietary Technology Platforms Support Our Business, page 70
1.We note your disclosure on page 71 that you have begun developing
Abacusmarketplace.com, and your reference to ABL Tech using blockchain capabilities
on page 14. Please disclose whether you have commenced business on these platforms. If
so, disclose the total number of transactions or sales that have occurred on each platform.
Also, for each operational platform, disclose how transactions are validated, and who
validates transactions and maintains the ledger. If you have not commenced business on
this platform, disclose the following: any known or anticipated material commitments for
capital expenditures, the sources of funds for such expenditures, and your expected timing
with respect to business development. Also, if you are dependent on third party vendors or
developers for the creation or operation of your blockchain, revise the disclosure to name
those vendors and clarify the reliance.

 FirstName LastNameJay J.  Jackson
 Comapany NameAbacus Life, Inc.
 May 21, 2024 Page 2
 FirstName LastName
Jay J.  Jackson
Abacus Life, Inc.
May 21, 2024
Page 2

2.We note your disclosure on page 71 that Abacusmarketplace.com will provide blockchain
tertiary trading, servicing and valuation platform for trading life insurance
policies. Please clarify, whether you are providing the underlying technology or whether
you will effectively operate the exchange or trading platform on behalf of your clients or
customers. Please provide us with a detailed explanation of how the
Abacusmarketplace.com platform acquires, transfers, and records the offer and sale of any
policies. Also, clarify the extent to which the platform will facilitate the sale of fractional
interests in a policy, and how the platform provides adequate actuarial data on the policy
to facilitate the evaluation of that policy, including any scoring provided by your other
platforms/products.
3.Provide us your analysis as to whether the operation of the Abacusmarketplace.com
platform impacts your obligations as a license producer of life settlements, if policies are
bought and sold using your product.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Aisha Adegbuyi at 202-551-8754 or Christian Windsor at 202-551-3419
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:       Ryan Maierson, Esq.