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 July 9, 2025

Tim Pickett
Chief Executive Officer and Chairman of the Board
Kindly MD, Inc.
5097 South 900 East Suite 100
Salt Lake City, UT 84117

 Re: Kindly MD, Inc.
 Information Statement on Schedule 14C
 Filed June 23, 2025
 File No. 001-42103
Dear Tim Pickett:

 We have reviewed your filing and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Information Statement on Schedule 14C filed June 23, 2025
Cover Page

1. We note your disclosure that you obtained approval of holders of
approximately
 50.76% of the outstanding voting power of the Company on May 18, 2025
and
 approximately 50.14% of the outstanding voting power of the Company on
June 19,
 2025 by written consents. However, the beneficial ownership table
included on page
 108 of the information statements shows that the directors and executive
officers of
 the Company only held approximately 40.79% of the outstanding voting
power of the
 Company as of June 1, 2025 and does not identify any shareholders
holding more than
 5% of the outstanding shares that are not already included in the 40.79%
total.
 Additionally, we note your disclosure in the Background of the Merger
section
 regarding the Shareholder Support Agreement and Lock-Up Agreement to be
signed
 by a majority of the Company's shareholders and your statement that
"[o]n April 18,
 2025, KindlyMD followed up with updated drafts of certain ancillary
documents,
 including note to the Shareholder Support Agreement and Lock-Up
Agreement
 indicating which KindlyMD shareholders had agreed to be party to such
 agreements." In your response letter, please identify the shareholders
who provided
 July 9, 2025
Page 2

 written consent for these actions, including each consenting stockholder
 s respective
 share ownership and relationship to the Company. Please also describe
the events that
 led to your receipt of the written consents and provide an analysis of
whether the
 process of obtaining the consents involved a solicitation within the
meaning of
 Exchange Act Rule 14a- 1(l).
Information about Nakamoto, page 38

2. Please expand your disclosure regarding your plan of operation for the
next twelve
 months by describing the source of capital for your acquisition of
bitcoin and any
 acquisition of, or investment in, companies that have bitcoin
treasuries. Please
 specify the amount of bitcoin currently held by Kindly MD or Nakamoto
and the
 amount of bitcoin you intend to purchase with the proceeds from the PIPE
Financing,
 the Additional Subscription Agreements, the Debt Financing, and the
Promissory
 Note with BTC so that investors understand the estimated size of the
bitcoin treasury
 of the Combined Company and your business strategy related to the
acquisition of, or
 investment in, companies that have bitcoin treasuries.
3. Please describe how you intend to generate bitcoin yield.
4. Please disclose an estimated timeline of the building of your bitcoin
treasury for the
 next twelve months, the implementation of your plans to generate bitcoin
yield, the
 acquisition and operation of companies in various industries that have
bitcoin
 treasuries and any planned investments in companies with bitcoin
treasuries. Include
 an estimate of the cost of each step, the sources of capital of each
step and the
 challenges you may face, including the payment of your debt obligations.
Adjustments to Unaudited Pro Forma Condensed Combined Statements of Operations,
page
F-7

5. We note you recorded pro forma adjustment (BB) and (DD) related to the
change in
 fair value of the company s Bitcoin investment for the pro forma
periods. Please
 provide us your analysis as to how the fair value adjustments comply
with Article 11
 pro forma guidance under Regulation S-X. In that regard, Item
11-02(a)(6)(i)(A) and
 (B) indicate that for a probable transaction pro forma adjustments
should be calculated
 using the most recent practicable date prior to the effective date,
qualification date or
 the mail date. As such, it is unclear why any change in fair value of
intangible assets
 would be recorded in your unaudited pro forma condensed combined
statements of
 operations.
 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.

 Please contact Conlon Danberg at 202-551-4466 or Lauren Nguyen at
202-551-3642
with any other questions.

 Sincerely,
 July 9, 2025
Page 3

 Division of Corporation Finance
 Office of Industrial Applications and
 Services
cc: Callie T. Jones, Esq.
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