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CORRESP
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filename1.htm

NEWLAN
LAW FIRM, PLLC

2201
Long Prairie Road, Suite 107-762

Flower
Mound, Texas 75022

October
5, 2023

Office
of Industrial Applications and Services

Division
of Corporation Finance

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

Re:       Ludwig
Enterprises, Inc.

Amendment
No. 4 to

Registration
Statement on Form S-1

Filed
September 18, 2023

File
No. 333-271439

Ladies
and Gentlemen:

This
is in response to the letter of comment of the Staff dated October 4, 2023, relating to the captioned Registration Statement on Form
S-1 of Ludwig Enterprises, Inc. (the “Company”). The comments of the Staff are addressed below, seriatim:

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.

Please
be advised that the disclosure has been revised, in response to this comment.

    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.

Please
be advised that the disclosure has been revised, in response to this comment.

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
be advised that the disclosure has been revised to refer to the Company’s having three named executive officers, in response to
this comment.

Please
be further advised that, where relevant, the disclosure has been revised to include a reference to Ms. Blackstone’s employment
agreement having been amended to remove CEO duties from her responsibilities, in response to this comment.

_____________________________

The
Company believes that this filing is now in order for effectiveness.

Please
feel free to contact the undersigned at (940) 367-6154, should you have any questions regarding any of the Company’s responses.

Thank
you for your attention in this matter.

Sincerely,

NEWLAN
LAW FIRM, PLLC

By:
/s/ Eric Newlan

Eric
Newlan

Managing
Member

cc:
Ludwig Enterprises, Inc.