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October 4, 2023
Martin Hausman, M.D.
Chief Executive Officer
LUDWIG ENTERPRISES, INC.
1749 Victorian Avenue, #C 350
Sparks, Nevada 89431
Re:LUDWIG ENTERPRISES, INC.
Amendment No. 4 to Registration Statement on Form S-1
Filed September 18, 2023
File No. 333-271439
Dear Martin Hausman:
            We have reviewed your amended registration statement and have the following
comment(s).
            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. Unless we note otherwise,
any references to prior comments are to comments in our September 2, 2023 letter.
Amendment No. 4 to Registration Statement on Form S-1
Management, page 47
1.We note your response to comments 3 and 7 and your revised disclosure here that Thomas
Terwilliger has served as your Chief Operating Officer, Treasurer and Secretary since
September 5, 2023. We further note that in your response letter dated August 17, 2023
you stated that, with respect to Exhibit A of Exhibit 10.10, which was your Consulting
Agreement with The Fannon Group, Mr. Terwilliger was included in "a list of Company
contacts" that included "certain of its consultants" with whom The Fannon Group would
interact. Please revise your disclosure here to discuss Mr. Terwilliger's experience with
the company prior to his being chosen to serve as an executive officer. Refer to Item
401(e)(1) of Regulation S-K.

 FirstName LastNameMartin Hausman, M.D.
 Comapany NameLUDWIG ENTERPRISES, INC.
 October 4, 2023 Page 2
 FirstName LastName
Martin Hausman, M.D.
LUDWIG ENTERPRISES, INC.
October 4, 2023
Page 2
2.We note the disclosure that Mr. Terwilliger "has founded and sold many start-up
businesses to NYSE and NASDAQ publicly traded companies such as MCI, Times Mirror
Publishing, ICG Corp., and Espire." Please revise to remove the implication that
businesses were "sold to NYSE and NASDAQ."  Also, if you include the names of
publicly traded companies, please clarify the company names and include the respective
ticker symbols. Last, describe the boards of the "numerous financial, Internet, Telephone
and R&D companies" that Mr. Terwilliger served on which you generally referred to
on page 47.
Executive Compensation, page 49
3.We note your response to comment 3 and your revised disclosure here and on page 52
discussing the employment agreements you have entered into with Dr. Hausman and Mr.
Terwilliger. Please revise your disclosure here to reflect that you now have three instead
of one named executive officer. Please also clarify whether the employment agreement
entered into with Anne Blackstone in June 2022 to serve as Chief Executive Officer has
been terminated and/or amended in connection with Dr. Hausman's appointment as CEO
on September 5, 2023 and related changes to Ms. Blackstone's position as an executive
and director of the company.
            Please contact Kristin Lochhead at 202-551-3664 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters. Please
contact Jessica Ansart at 202-551-4511 or Lauren Nguyen at 202-551-3642 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Eric Newlan