SecProbe.io

CORRESP
 1
 filename1.htm

 iSpecimen Inc.

 8 Cabot Road, Suite 1800

 Woburn, WA 08101

 January 28, 2026

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Re: iSpecimen Inc. Request for Acceleration

 Registration
Statement on Form S-3

 File No. 333-292804

 Ladies and Gentlemen:

 Pursuant to Rule 461 promulgated under the Securities
Act of 1933, as amended (the "Securities Act"), iSpecimen Inc., a Delaware corporation (the "Company"), respectfully
requests that the effective date of its registration statement on Form S-3 (File No. 333-292804) (the "Registration Statement"),
be accelerated so that it will become effective at 5:00 p.m., Eastern Time, on Friday, January 30, 2026, or as soon thereafter as possible.

 Once the Registration Statement is effective,
please confirm the event with our counsel, Sichenzia Ross Ference Carmel LLP by calling Ross D. Carmel, Esq. at (646) 838-1310.

 If you have any questions regarding this request,
please contact Ross D. Carmel, Esq. of Sichenzia Ross Ference Carmel LLP at (646) 838-1310.

 Very truly yours,

 By:
 /s/ Katharyn Field

 Name:
 Katharyn Field

 Title:
 Chief Executive Officer

 cc: Ross D. Carmel, Esq., Sichenzia Ross Ference
Carmel LLP

January 27, 2026
Katharyn Field
Chief Executive Officer
iSpecimen Inc.
8 Cabot Road, Suite 1800
Woburn, MA 01801
Re:iSpecimen Inc.
Registration Statement on Form S-3
Filed January 20, 2026
File No. 333-292804
Dear Katharyn Field:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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 Juan Grana at 202-551-6034 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and Services
cc:Benjamin E. Sklar, Esq.

CORRESP
 1
 filename1.htm

 WestPark Capital, Inc.

 1800 Century Park East, Suite 220

 Los Angeles, CA 90067

 July 21, 2025

 Via EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:
 iSpecimen Inc.

 Registration Statement on Form S-1

 File No. 333-286958

 Acceleration Request

 Requested Date:
 Wednesday, July 23, 2025

 Requested Time:
 4:30 PM Eastern Time

 Ladies and Gentlemen:

 Pursuant
to Rule 461 under the Securities Act of 1933, as amended (the "Securities Act"), WestPark Capital, Inc., as representative
of the underwriters of the offering, hereby joins the request of iSpecimen Inc. that the effective date of the above-referenced Registration
Statement on Form S-1 be accelerated so that it may become effective at 4:30 p.m., Eastern Time, on Wednesday, July 23, 2025, or as soon
thereafter as practicable.

 Pursuant
to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably
anticipated to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears
to be reasonable to secure adequate distribution of the preliminary prospectus.

 The
undersigned confirms that it has complied with and will continue to comply with, and it has been informed or will be informed by participating
dealers that they have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended.

 WESTPARK CAPITAL, INC.

 Very truly yours,

 By:
 /s/ Richard Rappaport

 Name:
 Richard Rappaport

 Title:
 Chief Executive Officer

CORRESP
 1
 filename1.htm

 iSpecimen Inc.

 8 Cabot Road, Suite 1800

 Mt Woburn, WA 08101

 July 21, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Industrial Applications and Services

 100 F Street, N.E.

 Washington, D.C. 20549

 Re: iSpecimen Inc. Request for Acceleration

 Registration Statement on Form S-1

 File No. 333-286958

 Ladies and Gentlemen:

 Pursuant to Rule 461 promulgated under the Securities
Act of 1933, as amended (the " Securities Act "), iSpecimen Inc., a Delaware corporation (the " Company "),
respectfully requests that the effective date of its Registration Statement on Form S-1 (File No. 333-286958), as amended (the " Registration
Statement "), be accelerated so that it will become effective at 4:30 p.m., Eastern Time, on Wednesday, July 23, 2025, or as
soon thereafter as possible.

 In making this acceleration request, the Company
acknowledges that:

 (i)
 should the Securities and Exchange Commission (the " Commission ") or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

 (ii)
 the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy of the disclosure in the Registration Statement; and

 (iii)
 the Company may not assert comments of the Commission or the staff and the declaration of effectiveness of the Registration Statement as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 Once the Registration Statement is effective,
please orally confirm the event with our counsel, Sichenzia Ross Ference Carmel LLP, by calling Ross D. Carmel, Esq. at (646) 838-1310.
We also respectfully request that a copy of the written order from the Commission verifying the effective time and date of the Registration
Statement be sent to our counsel, Sichenzia Ross Ference Carmel LLP, Attention: Ross D. Carmel, Esq., by email at rcarmel@srfc.law.

 If you have any questions regarding this request,
please contact Ross D. Carmel, Esq. a Sichenzia Ross Ference Carmel LLP at (646) 838-1310.

 Very truly yours,

 By:
 /s/ Robert Bradley Lim

 Name:
 Robert Bradley Lim

 Title:
 Chief Executive Officer

 cc: Ross D. Carmel, Esq., Sichenzia Ross Ference Carmel LLP

CORRESP
 1
 filename1.htm

 WestPark Capital, Inc.

 1800 Century Park East, Suite 220

 Los Angeles, CA 90067

 July 14, 2025

 Via EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:
 iSpecimen Inc.

 Registration Statement on Form S-1

 File No. 333-286958

 WITHDRAWAL OF ACCELERATION
REQUEST

 Ladies and Gentlemen:

 Reference is made to our letter, filed as correspondence
via EDGAR on July 10, 2025, in which we, as representative of the underwriters of the proposed public offering of securities of iSpecimen
Inc. (the "Company"), joined the Company's request for acceleration of the effective date of the above-referenced Registration
Statement for Monday, July 14, 2025, at 4:30 p.m. Eastern Time. The Company is no longer requesting that such Registration Statement be
declared effective at this time, and we hereby formally withdraw our request for acceleration of the effective date.

 Very truly yours,

 WESTPARK CAPITAL, INC.

 By:
 /s/ Richard Rappaport

 Name:
 Richard Rappaport

 Title:
 Chief Executive Officer

CORRESP
 1
 filename1.htm

 ISPECIMEN INC.

 8 Cabot Road, Suite 1800

 Woburn, MA 01801

 July 14, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC. 20549
Attn: Nicholas O'Leary/Margaret Sawicki

 Re:
 iSpecimen Inc.

 Withdrawal of Acceleration Request for Registration Statement on Form S-1

 File No. 333-286958

 Ladies and Gentlemen:

 Reference is made to our letter,
dated July 10, 2025, in which we requested acceleration of the effective date of the above referenced Registration Statement to
4:30 PM Eastern Daylight Time on July 14, 2025. We are no longer requesting that such Registration Statement be declared effective at
such time, and we hereby formally, and with immediate effect, withdraw our request for acceleration of the effective date.

 Very truly yours,

 iSpecimen Inc.

 By:
 /s/ Robert Lim

 Robert Lim

 Chief Executive Officer

CORRESP
 1
 filename1.htm

 iSpecimen Inc.

 8 Cabot Road, Suite 1800

 Mt Woburn, WA 08101

 July 10, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Industrial Applications and Services

 100 F Street, N.E.

 Washington, D.C. 20549

 Re: iSpecimen Inc. Request for Acceleration

 Registration
Statement on Form S-1

 File No. 333-286958

 Ladies and Gentlemen:

 Pursuant to Rule 461 promulgated under the Securities
Act of 1933, as amended (the " Securities Act "), iSpecimen Inc., a Delaware corporation (the " Company "),
respectfully requests that the effective date of its Registration Statement on Form S-1 (File No. 333-286958), as amended (the " Registration
Statement "), be accelerated so that it will become effective at 4:30 p.m., Eastern Time, on Monday, July 14, 2025, or as soon
thereafter as possible.

 In making this acceleration request, the Company
acknowledges that:

 (i)
 should the Securities and Exchange Commission (the " Commission ") or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

 (ii)
 the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy of the disclosure in the Registration Statement; and

 (iii)
 the Company may not assert comments of the Commission or the staff and the declaration of effectiveness of the Registration Statement as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 Once the Registration Statement is effective,
please orally confirm the event with our counsel, Sichenzia Ross Ference Carmel LLP, by calling Ross D. Carmel, Esq. at (646) 838-1310.
We also respectfully request that a copy of the written order from the Commission verifying the effective time and date of the Registration
Statement be sent to our counsel, Sichenzia Ross Ference Carmel LLP, Attention: Ross D. Carmel, Esq., by email at rcarmel@srfc.law.

 If you have any questions regarding this request,
please contact Ross D. Carmel, Esq. a Sichenzia Ross Ference Carmel LLP at (646) 838-1310.

 Very truly yours,

 By:
 /s/ Robert Bradley Lim

 Name:
 Robert Bradley Lim

 Title:
 Chief Executive Officer

 cc: Ross D. Carmel, Esq., Sichenzia Ross Ference
Carmel LLP

CORRESP
 1
 filename1.htm

 WestPark Capital, Inc.

 1800 Century Park East, Suite 220

 Los Angeles, CA 90067

 July 10, 2025

 Via EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:
 iSpecimen Inc.

 Registration Statement on Form S-1

 File No. 333-286958

 Acceleration Request

 Requested Date:
 Monday, July 14, 2025

 Requested Time:
 4:30 PM Eastern Time

 Ladies and Gentlemen:

 Pursuant
to Rule 461 under the Securities Act of 1933, as amended (the "Securities Act"), WestPark Capital, Inc., as representative
of the underwriters of the offering, hereby joins the request of iSpecimen Inc. that the effective date of the above-referenced Registration
Statement on Form S-1 be accelerated so that it may become effective at 4:30 p.m., Eastern Time, on Monday, July 14, 2025, or as soon
thereafter as practicable.

 Pursuant
to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably
anticipated to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears
to be reasonable to secure adequate distribution of the preliminary prospectus.

 The
undersigned confirms that it has complied with and will continue to comply with, and it has been informed or will be informed by participating
dealers that they have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended.

 WESTPARK CAPITAL, INC.

 Very truly yours,

 By:
 /s/ Richard Rappaport

 Name:
 Richard Rappaport

 Title:
 Chief Executive Officer

CORRESP
 1
 filename1.htm

 June 27, 2025

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Industrial
Applications and Services

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn:
 Mr. O'Leary / Ms. Sawicki

 Re:

 iSpecimen Inc.
 Amendment No. 2 to Registration Statement on Form S-1
 Filed June 11, 2025
 File No. 333-286958

 Dear Mr. O'Leary and Ms. Sawicki:

 On behalf of iSpecimen Inc. (the " Company "),
we have set forth below a response to the comment of the staff (the " Staff ") of the Securities and Exchange Commission
(the " SEC ") contained in its letter dated June 24, 2025 with respect to the Company's Amendment No. 2 to Registration
Statement on Form S-1 as noted above. For your convenience, the text of the Staff's comment is set forth below in bold, followed
by the Company's response.

 Amendment No. 2 to Registration Statement on
Form S-1 filed June 11, 2025

 Prospectus Summary, page 11

 1. We note your revisions in response to prior
comment 1. We reissue in part. Please revise to provide the material terms of the agreement for IR Agency LLC, filed as Exhibit 10.45,
including termination provisions. We note item 4(a) of the consulting agreement with IR Agency that states "[i]f the Agreement is
terminated by Client during the Term for any reason, Client will not be entitled to return of any of the compensation."

 Response : The Company has revised the disclosure
on page 11 to include the material terms of the agreement with IR Agency LLC, including that the compensation fee is fully earned upon
receipt and non-refundable if the Company terminates the agreement during the three-month term.

 We trust that the above is responsive to your
comment. Should you have any questions relating to the foregoing or wish to discuss any aspect of the Company's filing, please contact
Ross D. Carmel, Esq. at 646-838-1310.

 Sincerely,

 /s/ Ross D. Carmel, Esq.

 Ross D. Carmel, Esq.

 Sichenzia Ross Ference Carmel LLP

 1185 AVENUE OF THE AMERICAS
| 31ST FLOOR | NEW YORK, NY | 10036
 T (212) 930-9700 | F (212) 930-9725 | WWW.SRFC.LAW

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 June 24, 2025

Robert Lim
Chief Executive Officer
iSpecimen Inc.
8 Cabot Road, Suite 1800
Woburn, MA 01801

 Re: iSpecimen Inc.
 Amendment No. 2 to Registration Statement on Form S-1
 Filed June 11, 2025
 File No. 333-286958
Dear Robert Lim:

 We have reviewed your amended registration statement and have the
following
comment.

 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 June 9,
2025, letter.

Amendment No. 2 to Registration Statement on Form S-1 filed June 11, 2025
Prospectus Summary, page 11

1. We note your revisions in response to prior comment 1. We reissue in
part. Please
 revise to provide the material terms of the agreement for IR Agency LLC,
filed as
 Exhibit 10.45, including termination provisions. We note item 4(a) of
the consulting
 agreement with IR Agency that states "[i]f the Agreement is terminated
by Client
 during the Term for any reason, Client will not be entitled to return of
any of the
 compensation."
 June 24, 2025
Page 2

 Please contact Nicholas O'Leary at 202-551-4451 or Margaret Sawicki at
202-551-
7153 with any other questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Industrial
Applications and
 Services
cc: Ross Carmel, Esq.
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 June 11, 2025

 Via EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Industrial Applications and Services

 Attn:
 Mr. O'Leary and Ms. Sawicki

 Re:

 iSpecimen Inc.
 Amendment No. 1 to Registration Statement on Form S-1
 Filed May 23, 2025
 File No. 333-286958

 Dear Mr. O'Leary and Ms. Sawicki:

 On behalf of iSpecimen Inc. (the "Company"),
we have set forth below responses to the comments of the staff (the "Staff") of the Securities and Exchange Commission (the
"SEC") contained in its letter dated June 9, 2025 with respect to the Company's filing on May 23, 2025 of Amendment
No.1 to the Registration Statement on Form S-1 (the "S-1/A") as noted above. On behalf of the Company, Sichenzia Ross Ference
Carmel LLP ("we" or "our") is concurrently filing Amendment No. 2 to the S-1/A (the "Amendment No. 2").
Capitalized terms used herein but not defined herein have the definitions ascribed to them in Amendment No. 2.

 For your convenience, the text of the Staff's
comments is set forth below in bold, followed in each case by the Company's responses. Please note that all references to page numbers
in the responses are references to the page numbers in the S-1/A.

 Amendment No. 1 to Registration Statement on
Form S-1 filed May 23, 2025

 Prospectus Summary, page 1

 1. We note your revisions in response to prior
comment 1. We reissue in part. For the agreement with Sales Stack Solutions Corp., filed as Exhibit 10.46, please expand your disclosure
here to provide the material terms of this agreement, including the aggregate milestone payments due under the agreement, and state
whether any milestones have been met. We note Exhibit 10.46 states that the aggregate consideration payable to Sales Stack Solutions Corp.
is $2,400,000. Additionally, please expand your disclosure here to provide the material terms of the agreement with IR Agency LLC,
filed as Exhibit 10.45, including the term, termination provisions and extension provision. We also note that Exhibit 10.45 states
that the aggregate consideration payable to IR Agency LLC is $1,000,000, but this registration statement on Form S-1 states that
$1,500,000 of the net proceeds will be paid to IR Agency. Please reconcile these two figures.

 RESPONSE : The Company has revised the disclosure
in Amendment No. 2 to address the Staff's comments.

 Should you have any questions relating to the
foregoing or wish to discuss any aspect of the Company's filing, please contact me at 646-838-1310.

 Should you have any questions relating to the
foregoing or wish to discuss any aspect of the Company's filing, please contact our legal counsel, Ross D. Carmel, Esq., of Sichenzia
Ross Ference Carmel LLP, at rcarmel@srf.law or 646-838-1310.

 Sincerely,

 /s/ Robert Bradley Lim, Esq.

 Robert Bradley Lim, Esq.
 Chief Executive Officer

 iSpecimen Inc.

 1185 AVENUE OF THE AMERICAS
| 31ST FLOOR | NEW YORK, NY | 10036
T (212) 930-9700 | F (212) 930-9725 | WWW.SRFC.LAW

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 June 9, 2025

Robert Lim
Chief Executive Officer
iSpecimen Inc.
8 Cabot Road, Suite 1800
Woburn, MA 01801

 Re: iSpecimen Inc.
 Amendment No. 1 to Registration Statement on Form S-1
 Filed May 23, 2025
 File No. 333-286958
Dear Robert Lim:

 We have reviewed your amended registration statement and have the
following
comment.

 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 May 16,
2025, letter.

Amendment No. 1 to Registration Statement on Form S-1 filed May 23, 2025
Prospectus Summary, page 1

1. We note your revisions in response to prior comment 1. We reissue in
part. For the
 agreement with Sales Stack Solutions Corp., filed as Exhibit 10.46,
please expand
 your disclosure here to provide the material terms of this agreement,
including the
 aggregate milestone payments due under the agreement, and state whether
any
 milestones have been met. We note Exhibit 10.46 states that the
aggregate
 consideration payable to Sales Stack Solutions Corp. is $2,400,000.
Additionally,
 please expand your disclosure here to provide the material terms of the
agreement
 with IR Agency LLC, filed as Exhibit 10.45, including the term,
termination
 provisions and extension provision. We also note that Exhibit 10.45
states that the
 aggregate consideration payable to IR Agency LLC is $1,000,000, but this
registration
 June 9, 2025
Page 2

 statement on Form S-1 states that $1,500,000 of the net proceeds will be
paid to IR
 Agency. Please reconcile these two figures.
 Please contact Nicholas O'Leary at 202-551-4451 or Margaret Sawicki at
202-551-
7153 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
cc: Ross Carmel, Esq.
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 May 23, 2025

 Via EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Industrial Applications and Services

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn:
 Mr. O'Leary / Ms. Sawicki

 Re:

 iSpecimen Inc.
 Registration Statement on Form S-1
 Submitted May 2, 2025
 File No. 333-286958

 Dear Mr. O'Leary and Ms. Sawicki:

 On behalf of iSpecimen Inc. (the " Company "),
we have set forth below responses to the comments of the staff (the " Staff ") of the Securities and Exchange Commission
(the " SEC ") contained in its letter dated May 16, 2025 with respect to the Company's Registration Statement on
Form S-1 (the " S-1 ") as noted above.

 For your convenience, the text of the Staff's
comments is set forth below in bold, followed in each case by the Company's responses. Please note that all references to page numbers
in the responses are references to the page numbers in the S-1/A being filed herewith.

 Registration Statement on Form S-1 filed May
2, 2025

 Prospectus Summary, page 11

 1. We note you expect to receive $2,770,000 in net proceeds from
this offering and you intend to use approximately $1,000,000 of the net proceeds to fund the initial milestone payment to Sales
Stack Solutions Corp. "for the acquisition, integration, and maintenance of the SalesStack technology platform." We note Section
6 of the term sheet with Sales Stack Solutions Corp., filed as Exhibit 10.46, states: "this Term Sheet is intended as a statement
of mutual intentions and does not constitute a binding obligation on either party. Binding obligations will arise only upon the execution
and delivery of the definitive agreement." Please revise the prospectus to discuss the material terms of this term sheet and please
disclose clearly if there are any risks stemming from the non-binding nature of this term sheet. If there are risks, please revise to
discuss the potential consequences if the definitive agreement is not executed and delivered. Additionally, we note you intend
to use approximately $1,000,000 of the net proceeds for "marketing and advertising services" to be provided by IR Agency LLC. Please expand
your disclosure here to discuss the material terms of this agreement. Finally, disclose if either party is a related party pursuant
to Item 404 of Regulation S-K.

 In responses to the Staff's comment,
we wish to advise the Staff that the Company has entered into a binding Definitive Software Purchase and Services Agreement (the
"Agreement") with Sales Stack Solutions Corp. ("Sales Stack") pursuant to which Sales Stack will integrate
and maintain its software technology with the Company's existing platform. The Agreement is being filed as new Exhibit 10.46
to the S-1/A. The Company intends to use $1,000,000 of the net proceeds of this offering to pay Sales Stack upon its completion of
the building and installation of Sales Stack's technology into the Company's platform.

 1185 AVENUE OF THE AMERICAS
| 31ST FLOOR | NEW YORK, NY | 10036

 T (212) 930-9700 | F (212) 930-9725 | WWW.SRFC.LAW

 The Company also presently intends to use up to
$1.5 million of net proceeds to pay for marketing and advertising services to be provided by IR Agency LLC ("IR"). The Company
has expanded its disclosure on page 12 of the S-1/A to further describe its agreement with IR.

 The Company confirms that neither Sales Stack
nor IR are related parties pursuant to Item 404 of Regulation S-K.

 Use of Proceeds, page 12

 2 .
 We note the sensitivity analysis provided in the use of proceeds table. Given
this is a firm commitment offering, please explain to us why you included a sensitivity analysis. Please also revise the table to depict
the use of proceeds that the Company states the intended uses are for. Specifically, we note your disclosure on page 12 that the intended
uses are for "approximately $1,000,000 of the net proceeds for marketing and advertising services to be provided by IR Agency LLC,"
"approximately $1,000,000 of the net proceeds to fund the initial milestone payment to Sales Stack Solutions Corp., a British Columbia
company, pursuant to a signed term sheet for the acquisition, integration, and maintenance of the SalesStack technology platform,"
and the "remaining net proceeds will be used for working capital and general corporate purposes." Therefore, it is unclear
why you list other and more general uses of proceeds in this table.

 In response to the Staff's comment, the Company has revised its
disclosure on page 12 of the S-1/A to delete the sensitivity analysis and provide a new Use of Proceeds table reflecting the currently
expected offering proceeds of approximately $4 million.

 Incorporation of Certain Information by Reference,
page 23

 3 .
 Please revise to incorporate by reference each of the current reports on Form
8-K required pursuant to Item 12(a)(2) of Form S-1, which requires incorporation by reference of all current reports filed pursuant to
Section 13(a) or 15(d) of the Exchange Act since the end of the fiscal year covered by the registrant's latest annual report on Form 10-K.

 In response to the Staff's comment, the
Company has revised its disclosure on page 23 to specifically identify (i) all Current Reports on Form 8-K filed by the Company since
the end of fiscal year 2024, (ii) the Company's Quarterly Report on Form 10-Q for the period ended March 31, 2025, filed on May
19, 2025 and (iii) the Company's Annual report on Form 10-K for the fiscal year ended December 31, 2024, filed on April 14, 2025
and has incorporated all of such reports by reference.

 Signatures, page II-10

 4 .
 Instruction 1 to Signatures on Form S-1 requires, in relevant part, that the
registration statement is signed by the company's principal financial officer, controller or principal accounting officer. If the
person who performs the functions of your principal financial officer, controller or principal accounting officer currently has a signature
line on the registration statement, please revise the corresponding parenthetical descriptor under the Title column to indicate that such
person is, or also is, signing in the capacity of your principal financial officer, controller or principal accounting officer. We note
that the certification of your "Principal Financial Officer" filed as Exhibit 31.2 to your Form 10-K for the year-ended December
31, 2024, was signed by Yuying Liang, who has not signed this registration statement, as your "Principal Accounting and Financial
Officer."

 In response to the Staff's comment, the
Company has included the signature of Ms. Yuying Liang on the S-1/A as the Company's Principal Accounting and Financial Officer.

 1185 AVENUE OF THE AMERICAS
| 31ST FLOOR | NEW YORK, NY | 10036

 T (212) 930-9700 | F (212) 930-9725 | WWW.SRFC.LAW

 2

 We trust that the above is responsive to your
comments.

 Should you have any questions relating to the
foregoing or wish to discuss any aspect of the Company's filing, please contact me at 646-838-4433.

 Sincerely,

 /s/ Barry P. Biggar

 Cc: Robert Lim- iSpecimen Inc.
 Barry P. Biggar, Esq.

 Sichenzia Ross Ference Carmel LLP

 1185 AVENUE OF THE AMERICAS
| 31ST FLOOR | NEW YORK, NY | 10036

 T (212) 930-9700 | F (212) 930-9725 | WWW.SRFC.LAW

 3

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 16, 2025

Robert Lim
Chief Executive Officer
iSpecimen Inc.
8 Cabot Road, Suite 1800
Woburn, MA 01801

 Re: iSpecimen Inc.
 Registration Statement on Form S-1
 Filed May 2, 2025
 File No. 333-286958
Dear Robert Lim:

 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 filed May 2, 2025
Prospectus Summary, page 1

1. We note you expect to receive $2,770,000 in net proceeds from this
offering and you
 intend to use approximately $1,000,000 of the net proceeds to fund the
initial
 milestone payment to Sales Stack Solutions Corp. "for the acquisition,
integration,
 and maintenance of the SalesStack technology platform." We note Section
6 of the
 term sheet with Sales Stack Solutions Corp., filed as Exhibit 10.46,
states: "this Term
 Sheet is intended as a statement of mutual intentions and does not
constitute a binding
 obligation on either party. Binding obligations will arise only upon the
execution and
 delivery of the definitive agreement." Please revise the prospectus to
discuss the
 material terms of this term sheet and please disclose clearly if there
are any risks
 stemming from the non-binding nature of this term sheet. If there are
risks, please
 revise to discuss the potential consequences if the definitive agreement
is not executed
 May 16, 2025
Page 2

 and delivered. Additionally, we note you intend to use approximately
$1,000,000 of
 the net proceeds for "marketing and advertising services" to be provided
by IR
 Agency LLC. Please expand your disclosure here to discuss the material
terms of this
 agreement. Finally, disclose if either party is a related party pursuant
to Item 404 of
 Regulation S-K.
Use of Proceeds, page 12

2. We note the sensitivity analysis provided in the use of proceeds table.
Given this is a
 firm commitment offering, please explain to us why you included a
sensitivity
 analysis. Please also revise the table to depict the use of proceeds
that the Company
 states the intended uses are for. Specifically, we note your disclosure
on page 12 that
 the intended uses are for "approximately $1,000,000 of the net proceeds
for marketing
 and advertising services to be provided by IR Agency LLC,"
"approximately
 $1,000,000 of the net proceeds to fund the initial milestone payment to
Sales Stack
 Solutions Corp., a British Columbia company, pursuant to a signed term
sheet for the
 acquisition, integration, and maintenance of the SalesStack technology
platform," and
 the "remaining net proceeds will be used for working capital and general
corporate
 purposes." Therefore, it is unclear why you list other and more general
uses of
 proceeds in this table.
Incorporation of Certain Information by Reference, page 23

3. Please revise to incorporate by reference each of the current reports on
Form 8-K
 required pursuant to Item 12(a)(2) of Form S-1, which requires
incorporation by
 reference of all current reports filed pursuant to Section 13(a) or
15(d) of the
 Exchange Act since the end of the fiscal year covered by the
registrant's latest annual
 report on Form 10-K.
Signatures, page II-10

4. Instruction 1 to Signatures on Form S-1 requires, in relevant part, that
the registration
 statement is signed by the company's principal financial officer,
controller or principal
 accounting officer. If the person who performs the functions of your
principal
 financial officer, controller or principal accounting officer currently
has a signature
 line on the registration statement, please revise the corresponding
parenthetical
 descriptor under the Title column to indicate that such person is, or
also is, signing in
 the capacity of your principal financial officer, controller or
principal accounting
 officer. We note that the certification of your "Principal Financial
Officer" filed as
 Exhibit 31.2 to your Form 10-K for the year-ended December 31, 2024, was
signed by
 Yuying Liang, who has not signed this registration statement, as your
"Principal
 Accounting and Financial Officer."
 May 16, 2025
Page 3

 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 Nicholas O'Leary at 202-551-4451 or Margaret Sawicki at
202-551-
7153 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
cc: Ross Carmel, Esq.
</TEXT>
</DOCUMENT>

CORRESP
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WestPark Capital, Inc.

1800 Century Park East, Suite 220

Los Angeles, CA 90067

October 28, 2024

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Re: iSpecimen Inc.

Registration Statement on Form S-1

File No. 333-282736

REQUEST FOR ACCELERATION OF EFFECTIVENESS

Requested
Date:    Tuesday, October 29, 2024

Requested Time:   5:00
p.m., Eastern Time

Ladies and Gentlemen:

Pursuant to Rule 461
under the Securities Act of 1933, as amended (the “Securities Act”), we, as the placement agent of the proposed public offering
on a best efforts basis of securities of iSpecimen Inc. (the “Company”), hereby join the Company’s request that the
effective date of the above-referenced registration statement on Form S-1, be accelerated so that it will be declared effective at
5:00 p.m., Eastern Daylight Time, on Tuesday, October 29, 2024, or as soon thereafter as possible.

Pursuant to Rule 460
under the Securities Act, please be advised that we will distribute as many copies of the proposed form of preliminary prospectus as appears
to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned advises that
it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

    Very truly yours,

    WestPark Capital, Inc.

    By:
    /s/ Richard Rappaport

    Name:
    Richard Rappaport

    Title:
    Chief Executive Officer

CORRESP
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 iSpecimen Inc.

8 Cabot Road, Suite 1800

Mt Woburn, WA 08101

October 28, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Industrial Applications and Services

100 F Street, N.E.

Washington, D.C. 20549

Re: iSpecimen Inc. Request for
Acceleration

Registration
Statement on Form S-1

File No. 333-282736

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the
Securities Act of 1933, as amended (the “Securities Act”), iSpecimen Inc., a Delaware corporation (the “Company”),
respectfully requests that the effective date of its Registration Statement on Form S-1 (File No. 333-282736), as amended (the
 “Registration Statement”), be accelerated so that it will become effective at 5:00 p.m., Eastern Time, on Tuesday,
October 29, 2024, or as soon thereafter as possible.

In making this acceleration request, the Company
acknowledges that:

    (i)
    should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

    (ii)
    the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy of the disclosure in the Registration Statement; and

    (iii)
    the Company may not assert comments of the Commission or the staff and the declaration of effectiveness of the Registration Statement as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Once the Registration Statement is effective,
please orally confirm the event with our counsel, Sichenzia Ross Ference Carmel LLP, by calling Ross D. Carmel, Esq. at (646) 838-1310.
We also respectfully request that a copy of the written order from the Commission verifying the effective time and date of the Registration
Statement be sent to our counsel, Sichenzia Ross Ference Carmel LLP, Attention: Ross D. Carmel, Esq., by email at rcarmel@srfc.law.

If you have any questions regarding this request,
please contact Ross D. Carmel, Esq. a Sichenzia Ross Ference Carmel LLP at (646) 838-1310.

    Very truly yours,

    By:
    /s/ Tracy Curley

    Name:
    Tracy Curley

    Title:
    Chief Executive Officer

cc: Ross D. Carmel, Esq., Sichenzia Ross
Ference Carmel LLP

October 24, 2024
Tracy Curley
Chief Executive Officer
iSpecimen Inc.
8 Cabot Road, Suite 1800
Woburn, MA 01801
Re:iSpecimen Inc.
Registration Statement on Form S-1
Filed October 18, 2024
File No. 333-282736
Dear Tracy Curley:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:Benjamin Sklar, Esq.

United States securities and exchange commission logo
August 3, 2022
Christopher Ianelli
Chief Executive Officer
iSpecimen Inc.
450 Bedford Street
Lexington, MA 02420
Re:iSpecimen Inc.
Registration Statement on Form S-3
Filed July 29, 2022
File No. 333-266384
Dear Mr. Ianelli:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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 Alyssa Wall at 202-551-8106 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Scott M. Miller, Esq.

CORRESP
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iSpecimen Inc.

450 Bedford Street

Lexington, MA 02420

August 3, 2022

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C.  20549

Attention: Alyssa Wall

    Re:
    iSpecimen Inc.

    Registration Statement on Form S-3

    Filed July 29, 2022

    File No. 333-266384

Dear Ms. Wall:

Pursuant to Rule 461
under the Securities Act of 1933, as amended, iSpecimen Inc. hereby requests acceleration of effectiveness of the above referenced Registration
Statement on Form S-3 so that it will become effective at 4:00 p.m. ET on Friday, August 5, 2022, or as soon as thereafter
practicable.

    Very truly yours,

    /s/ Christopher Ianelli

    Christopher Ianelli

    Chief Executive Officer

cc:    Ellenoff
Grossman & Schole LLP

CORRESP
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iSpecimen Inc.

450 Bedford Street

Lexington, MA 02420

July 8, 2022

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C.  20549

Attention: Ryan Lichtenfels

    Re:
    iSpecimen Inc.

Registration Statement on Form S-3

Filed July 1, 2022

File No. 333-265976

Dear Mr. Lichtenfels:

Pursuant to Rule 461
under the Securities Act of 1933, as amended, iSpecimen Inc. hereby requests acceleration of effectiveness of the above referenced Registration
Statement on Form S-3 so that it will become effective at 4:00 p.m. ET on Tuesday, July 12, 2022, or as soon as thereafter
practicable.

    Very truly yours,

    /s/ Christopher Ianelli

    Christopher Ianelli

    Chief Executive Officer

    cc:
    Ellenoff Grossman & Schole LLP

United States securities and exchange commission logo
July 8, 2022
Tracy Curley
Chief Financial Officer
iSpecimen Inc.
450 Bedford Street
Lexington, MA 02420
Re:iSpecimen Inc.
Registration Statement on Form S-3
Filed July 1, 2022
File No. 333-265976
Dear Ms. Curley:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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 Ryan Lichtenfels at 202-551-4457 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Scott Miller

CORRESP
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iSpecimen Inc.

450 Bedford Street

Lexington, MA 02420

December 21, 2021

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C.  20549

Attention: Jennie Beysolow

    Re:
    iSpecimen Inc.

Registration Statement on Form S-1

Filed December 14, 2021

File No. 333-261640

Dear Ms. Beysolow:

Pursuant to Rule 461
under the Securities Act of 1933, as amended, iSpecimen Inc. hereby requests acceleration of effectiveness of the above referenced Registration
Statement so that it will become effective at 4:00 p.m. ET on Thursday, December 23, 2021, or as soon as thereafter practicable.

    Very truly yours,

    /s/ Christopher Ianelli

    Christopher Ianelli

    Chief Executive Officer

    cc:
    Ellenoff Grossman & Schole LLP

United States securities and exchange commission logo
December 21, 2021
Christopher Ianelli
President and Chief Executive Officer
iSpecimen Inc.
450 Bedford Street
Lexington, MA 02420
Re:iSpecimen Inc.
Registration Statement on Form S-1
Filed December 14, 2021
File No. 333-261640
Dear Mr. Ianelli:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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 Jennie Beysolow at 202-551-8108 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Barry I. Grossman

CORRESP
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iSpecimen Inc.

450 Bedford Street

Lexington, MA 02420

June 14, 2021

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C.  20549

Attention: Katherine Bagley

    Re:
    iSpecimen Inc.

Registration Statement on Form S-1

Filed November 19, 2020, as amended

File No. 333-250198

Dear Ms. Bagley:

Pursuant to Rule 461
under the Securities Act of 1933, as amended, iSpecimen Inc. hereby requests acceleration of effectiveness of the above referenced Registration
Statement so that it will become effective at 5:00 p.m. ET on Wednesday, June 16, 2021, or as soon as thereafter practicable.

    Very truly yours,

    /s/ Christopher Ianelli

    Christopher Ianelli

    Chief Executive Officer

    cc:
    Ellenoff Grossman & Schole LLP

CORRESP
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ThinkEquity

A division of Fordham Financial Management, Inc.

17
State Street, 22nd Floor

New York, NY 10004

June 14,
2021

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporate Finance

100 F St., NE

Washington, D.C. 20549

 Re: iSpecimen Inc.

Registration
Statement on Form S-1

Ladies and Gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of
1933, as amended, ThinkEquity, a division of Fordham Financial Management, Inc., as representative of the underwriters, hereby requests
acceleration of the effective date of the above-referenced Registration Statement so that it will become effective at 5:00 p.m. Eastern
Time on Wednesday, June 16, 2021, or as soon thereafter as practicable.

Pursuant
to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter, who is reasonably anticipated
to be invited to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears
to be reasonable to secure adequate distribution of the preliminary prospectus.

The
undersigned confirms that it has complied with and will continue to comply with, and it has been informed or will be informed by participating
dealers that they have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended,
in connection with the above-referenced issue.

    Very truly yours,

    ThinkEquity

    A division of Fordham Financial Management, Inc.

    By:
    /s/ Priyanka Mahajan

    Name:
    Priyanka Mahajan

    Title:
    Managing Director, Investment Banking

CORRESP
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iSpecimen Inc.

450 Bedford Street

Lexington, MA 02420

VIA EDGAR

April 27, 2021

U.S. Securities & Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, NE

Washington, D.C. 20549

Attn: Katherine Bagley

      Re: iSpecimen Inc.

Amendment No. 3 to Registration
Statement on Form S-1

Filed April 2, 2021

File No. 333-250198

Dear Ms. Bagley:

iSpecimen, Inc.
(the “Company,” “we,” “our” or “us”) hereby transmits the
Company’s response to the comment letter received from the staff (the “Staff”) of the U.S. Securities and Exchange
Commission (the “Commission”), on April 26, 2021, regarding Amendment No. 3 to Registration Statement on
Form S-1 submitted to the Commission on April 2, 2021. For the Staff’s convenience, we have repeated below the Staff’s
comments in bold, and have followed each comment with the Company’s response.

Amendment No. 3 to Registration Statement
on Form S-1, filed April 2, 2021

Management's Discussion and Analysis of
Financial Condition and Results of Operations Liquidity and Capital Resources

Factoring Agreement, page 56

 1. Please disclose the material terms of the factoring agreement and explain how it works, including the
significance of it being without recourse and the discount at which you sell the receivables. In addition, please file the agreement as
an exhibit to the registration statement, or tell us why you do not believe you are required to do so. See Item 601(b)(10) of Regulation
S-K.

Response: In response to the comment, we have
revised the disclosures on page 57 and filed the factoring agreement as an exhibit to the registration statement.

Balance Sheets, page F-3

 2. It appears that you have removed previously requested disclosure regarding what your deferred revenue
relates to and how it arose. Please revise to include this disclosure.

Response: In response to the comment, we have
revised the disclosures on pages 53, 60 and F-11.

      1

We thank the Staff for its
review of the foregoing and the Registration Statement. If you have further comments, please feel free to contact to our counsel, Lijia
Sanchez, at lsanchez@egsllp.com or by telephone at (212) 370-1300.

  Sincerely,

  /s/ Christopher Ianelli

  Christopher Ianelli, Chief Executive Officer

cc: Lijia Sanchez, Esq.

      2

United States securities and exchange commission logo
April 26, 2021
Christopher Ianelli
Chief Executive Officer
iSpecimen Inc.
450 Bedford Street
Lexington, MA 02420
Re:iSpecimen Inc.
Amendment No. 3 to Registration Statement on Form S-1
Filed April 2, 2021
File No. 333-250198
Dear Mr. Ianelli:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our February 1, 2021 letter.
Amendment No. 3 to Registration Statement on Form S-1, filed April 2, 2021
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources
Factoring Agreement, page 56
1.Please disclose the material terms of the factoring agreement and explain how it works,
including the significance of it being without recourse and the discount at which you sell
the receivables. In addition, please file the agreement as an exhibit to the registration
statement, or tell us why you do not believe you are required to do so.  See Item
601(b)(10) of Regulation S-K.

 FirstName LastNameChristopher Ianelli
 Comapany NameiSpecimen Inc.
 April 26, 2021 Page 2
 FirstName LastName
Christopher Ianelli
iSpecimen Inc.
April 26, 2021
Page 2
Balance Sheets, page F-3
2.It appears that you have removed previously requested disclosure regarding what your
deferred revenue relates to and how it arose. Please revise to include this disclosure.
            You may contact Aamira Chaudhry at (202) 551-3389 or Lyn Shenk at (202) 551-3380 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Katherine Bagley at (202) 551-2545 or Dietrich King at (202) 551-8071 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Barry I. Grossman

CORRESP
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iSpecimen Inc.

450 Bedford Street

Lexington, MA 02420

VIA EDGAR

April 1, 2021

U.S. Securities & Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, NE

Washington, D.C. 20549

Attn: Aamira Chaudhry

Re:        iSpecimen
Inc.

Amendment No. 2 to Registration Statement
on Form S-1

Filed January 20, 2021

File No. 333-250198

Dear Ms. Chaudhry:

iSpecimen, Inc. (the
 “Company,” “we,” “our” or “us”) hereby transmits the Company’s
response to the comment letter received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission
(the “Commission”), on February 1, 2021, regarding Amendment No. 2 to Registration Statement on Form S-1 submitted
to the Commission on January 20, 2021. For the Staff’s convenience, we have repeated below the Staff’s comments in bold, and
have followed each comment with the Company’s response.

Amendment No. 2 to Registration Statement on Form S-1

Executive Compensation, page 95

 1. We note your response to comment 4, and your amended disclosure in your Summary
Compensation Table on page 95. Please amend the disclosure in the rest of your Executive Compensation section to include the required
information for your last completed fiscal year. In this regard, please amend your "Equity Incentive Plans," "Outstanding
Equity Awards at Fiscal Year End," and "Non-Employee Director Compensation" disclosures to include information for your
fiscal year ended December 31, 2020.

Response:  	In response to the Staff’s
comment, the Company has revised the disclosures on pages 98 through 99.

    1

Notes to Financial Statements

Summary of Significant Accounting Policies

Revenue
Recognition and Accounts Receivable, page F-35

As comments 2 through 8 are related to our
revenue recognition policy, we would like to further clarify portions of our process, procedures, and policy to the Staff in this
overview and then provide the details requested as related to each comment.

Three major steps exist in the specimen procurement
process:

 · Collection - “Collection” is when
the specimen has been removed, or “collected” from the patient or donor. Specimens may be collected by our suppliers for a
particular Company order (“custom collections”), for clinical purposes (“remnant specimens”), or collected and
banked by suppliers for some future unspecified research use (“banked specimens”). The supplier has control of the specimen
after it has been collected but before it has been assigned to the Company.

 · Assignment of a specimen to the Company –
A collected specimen that meets the Company’s requirements for a specific order (either because the specimen was collected specifically
for the Company or because it was previously collected for clinical care or unspecified research use) is assigned to the Company when
the supplier has validated the specimen is available and meets the Company’s requirements. The Company has control of the specimen
after it has been assigned to the Company by the supplier and before it has been accessioned.

  · Accession - Once the Company has validated that a specimen assigned to the Company by the supplier
                                                                         meets a customer’s order requirements, the associated data  is registered and assigned in the iSpecimen Marketplace to a
                                                                         particular customer order and the specimen is considered accessioned. The customer has control of the specimen once it has been
                                                                         accessioned.

We have concluded that we act as principal in the arrangement as we
manage the procurement process from beginning to end and determine which suppliers will be used to fulfill an order, usually take physical
possession of the specimens, set prices for the specimens, and bear the responsibility for customer credit risk.

We recognize revenue over time, as we have created an asset with no alternative use and we have an enforceable right to payment for performance
completed to date. We use an output method to recognize revenue for specimens with no alternative future use. The output is measured
based on the number of specimens accessioned.

 2. We note your response to our prior comment number 6. Your response letter dated
December 31, 2020 stated, “The hold was specifically related to circumstances whereby the supplier was not able to process the specimens
due to COVID-19 shutdowns.” However, in your current response you state, “The customer requested the supplier to hold portions
of the order at the supplier location, as the customer did not have available storage space in its facility to store the specimens before
using the specimens for their intended use.” These appear to be two entirely different sets of circumstances. Please tell us if
you had more than one bill and hold transaction. If not, please tell us how the circumstances surrounding the reason for the bill and
hold transaction changed. Please also tell us when this order was placed by the customer, when the customer requested the supplier to
hold portions of the order at the supplier location,
how this request was communicated to the supplier (i.e., directly or through the Company), and when this order was shipped by the supplier.

Response:     We would like to further clarify
to the Staff our evaluation of this transaction in accordance with our revenue recognition policy and then provide the details requested
related to this transaction.

    2

Additional Analysis

As detailed further in our response to
Comment #3, the Company recognizes revenue when a specimen is accessioned as that is when control of the specimen transfers to the
customer and the Company satisfies its performance obligation. The Company, however, typically does not invoice the customer until
specimens ship, unless the Company enters into a separate arrangement with the customer, as was done with the customer referenced in
this response. The specimens in question, which were originally evaluated as a “bill and hold” transaction, were
accessioned during the first quarter of 2020 and the related revenue and costs of revenue were recognized. While we originally
evaluated the guidance in ASC 10-55-83 (which is predicated on a point-in-time model in accordance with ASC 10-25-30) due to the
unusual nature of the request from our customer, we did not need to as our revenue recognition is pursuant to an over-time model in
accordance with ASC 606-10-25-27 (c). We acknowledge that our disclosure in the September 30, 2020 interim condensed financial
statements was not needed and have not included this disclosure in the December 31, 2020 financial statements.

Requested Background of Transaction

The customer submitted a purchase order to
the Company on December 12, 2019 and requested that the specimens be shipped to the customer’s third-party sequencer on its
behalf. The purchase order was comprised of thousands of  specimens, and the Company expected that the specimens would be
delivered to the customer in multiple batches. The first three batches were accessioned and sent to the third-party sequencer in
late December 2019 and early January 2020 (not part of the specimens initially evaluated).

Later in January 2020, when our supplier
site was ready to send the final four batches, the customer requested that these specimens be held  at the supplier because their
third-party sequencer would no longer receive specimens on behalf of the customer, as the customer’s contract with the
third-party sequencer had not yet been executed. The customer also did not have capacity to receive and store the specimens at their
own facility.

In February 2020, when the customer still had
not finalized their contract with the third-party sequencer, the Company began negotiating a formal amendment to the purchase order to
address payment and timing of shipment for the four remaining batches that were being held on the customer’s behalf.

In March 2020, the supplier, due to
COVID-19 could no longer ship the held specimens until it could resume operations
in the future.

Once the supplier resumed operations, during
the latter part of the second quarter of 2020, the specimens were shipped to the third-party sequencer. All shipments were completed
before the end of the second quarter of 2020.

 3. We note your response to our comment number 7. You state that your customers
obtain control of a specimen when a specimen is accessioned. As the supplier is responsible for collection of the specimen and has physical
possession of the specimen prior to accession, it appears the supplier may control the specimen prior to accession. Given this, please
tell us why you believe you control the specimen prior to it being accessioned. In your response, specifically address who has inventory
risk prior to accession and what discretion you and your suppliers have over pricing. Refer to ASC 606-10-55-39.

Response:     To
determine when the Company’s supplier has control of a specimen and when this control transfers to the Company, we examined the
relationship and contracts between the Company and its suppliers and evaluated who has control of the specimen from the time it was collected
(i.e. removed from a patient) through accessioning, when control transfers to the customer.

We concluded that the Company has control over
the specimen after the specimen has been created (i.e. collected), verified to meet the Company’s specification(s), and assigned
to the Company by the supplier and before it is accessioned.

    3

The assignment of the specimen to the
Company, is communicated to the Company when the supplier provides the Company with data about the assigned specimen. With the
assignment of the specimen by the supplier to the Company, the supplier’s performance obligation is satisfied. The supplier
has created an asset on the Company’s behalf; the asset generally has no alternative use to the supplier; the supplier has an
enforceable right to payment for the specimens assigned should the Company cancel the contract; and the Company has the ability to
direct the use of the specimens. As the supplier has an enforceable right to payment for performance completed to date, the Company
essentially receives the benefits of the supplier’s performance and therefore obtains control of the goods or services as the
supplier performs. So, in accordance with ASC 606 10-25-27(c), the Company controls a specimen after collection and assignment to
the Company by the supplier and before the specimen is accessioned.

We have concluded that the supplier has
control of the specimen after it has been collected but before the supplier has assigned it to the Company, the
Company has control of the specimen after it has been assigned to the Company but before the specimen has been accessioned, and the
customer has control of the specimen once it has been accessioned as follows:

The Company also considered the following
guidance in ASC 606-10-55-39 to determine whether the Company controls the specified good or service before it is transferred to the
customer (and therefore is a principal). In this guidance, the Company weighted a. and c. more heavily as we recognize
revenue overtime and b. (inventory risk) less heavily, due to how quickly the transfer of control to each party that takes place
and that the transactions are supported by an existing customer order. We do acknowledge that the supplier also has some inventory
risk.

The three elements were evaluated:

a. The entity is primarily responsible
for fulfilling the promise to provide the specified good or service. This typically includes responsibility for the acceptability of the
specified good or service (for example, primary responsibility for the good or service meeting customer specifications). If the entity
is primarily responsible for fulfilling the promise to provide the specified good or service, this may indicate that the other party involved
in providing the specified good or service is acting on the entity’s behalf.

In accordance with ASC 606-10-55-39(a), the
Company is responsible for procuring a specimen from a supplier meeting the requested specifications. The Company’s
performance obligation is satisfied when a specimen is accessioned. The Company also has the responsibility to ensure that all
specimens meet customer specifications, as detailed within the purchase order, and the Company has the primary responsibility to
ensure that customer issues are remedied if there are customer returns or issues with products delivered to the customer. The
supplier is acting on behalf of the Company’s direct instructions and has no direct knowledge of the customer nor its use for
the specimen, and the customer does not know which supplier the specimen was sourced from.

    4

b. The entity has inventory risk
before the specified good or service has been transferred to a customer or after transfer of control to the customer (for example, if
the customer has a right of return). For example, if the entity obtains, or commits to obtain, the specified good or service before obtaining
a contract with a customer, that may indicate that the entity has the ability to direct the use of, and obtain substantially all of the
remaining benefits from, the good or service before it is transferred to the customer.

In our previous response to the Staff we had indicated
that in the majority of the customer orders, we do not take physical possession of the specimens. However, in this response we would like
to clarify that in the majority of the cases, the Company does receive specimens before shipping them to a customer. In 2020 and 2019,
approximately 60% and 80%, respectively, of specimens shipped to customers were shipped to the Company first, before being shipped to
customers. Direct shipments from suppliers to customers (40% in 2020 and 20% in 2019) generally occur when specimens must be delivered
directly to the customer within a short time period (less than 24 hours after collection) or when shipping to the Company is not feasible
or desired (e.g. during 2020 with COVID-19 positive specimens, where we wanted to limit specimen handling).

We generally do not procure specimens ahead
of receiving a purchase order for them, nor do we generally invest in the creation and maintenance of any Company-controlled
inventory from which future purchase orders may be fulfilled. We have considered when the Company does take physical possession and
when it does not, and have determined that during the period when the Company has control of a specimen, the Company has inventory
risk. The Company controls a specimen, from the time that a specimen is assigned by the supplier to the Company to when the
specimen is accessioned.

We have also considered our returns policy
and because the Company performs various procedures such as validating, registering and assigning the specimen to the customer
during the accessioning process, the Company believes that, in effect, the customer has accepted the specimen at accession, and the
revenue can be recognized as specimens are accessioned. Customers accept 97-100% of all accessioned and shipped specimens, depending
upon the type (banked, clinical remnants, custom collections).

Due to the relatively brief amount of time that the Company has this
inventory risk and the volume of specimens in process on a given day, the Company’s inventory is immaterial for presentation
and disclosure within the financial statements.

Specimens Shipped to the Company from a Supplier

As mentioned, in 2020 and 2019,
approximately 60% and 80% of specimens, respectively, were shipped from suppliers to the Company before being shipped to a customer
by the Company. In 2020, of the approximately 60% of specimens shipped from the supplier to the Company, approximately 78% of these
were accessione

United States securities and exchange commission logo
February 1, 2021
Christopher Ianelli
Chief Executive Officer
iSpecimen Inc.
450 Bedford Street
Lexington, MA 02420
Re:iSpecimen Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed January 20, 2021
File No. 333-250198
Dear Mr. Ianelli:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our January 15, 2021 letter.
Amendment No. 2 to Registration Statement on Form S-1
Executive Compensation, page 95
1.We note your response to comment 4, and your amended disclosure in your Summary
Compensation Table on page 95. Please amend the disclosure in the rest of your Executive
Compensation section to include the required information for your last completed fiscal
year. In this regard, please amend your "Equity Incentive Plans," "Outstanding Equity
Awards at Fiscal Year End," and "Non-Employee Director Compensation" disclosures to
include information for your fiscal year ended December 31, 2020.

 FirstName LastNameChristopher Ianelli
 Comapany NameiSpecimen Inc.
 February 1, 2021 Page 2
 FirstName LastName
Christopher Ianelli
iSpecimen Inc.
February 1, 2021
Page 2
Notes to Financial Statements
Summary of Significant Accounting Policies
Revenue Recognition and Accounts Receivable, page F-35
2.We note your response to our prior comment number 6.  Your response letter dated
December 31, 2020 stated, “The hold was specifically related to circumstances whereby
the supplier was not able to process the specimens due to COVID-19 shutdowns.”
However, in your current response you state, “The customer requested the supplier to hold
portions of the order at the supplier location, as the customer did not have available
storage space in its facility to store the specimens before using the specimens for their
intended use.” These appear to be two entirely different sets of circumstances. Please tell
us if you had more than one bill and hold transaction. If not, please tell us how the
circumstances surrounding the reason for the bill and hold transaction changed. Please
also tell us when this order was placed by the customer, when the customer requested the
supplier to hold portions of the order at the supplier location, how this request was
communicated to the supplier (i.e., directly or through iSpecimen), and when this order
was shipped by the supplier.
3.We note your response to our comment number 7. You state that your customers obtain
control of a specimen when a specimen is accessioned. As the supplier is responsible for
collection of the specimen and has physical possession of the specimen prior to accession,
it appears the supplier may control the specimen prior to accession. Given this, please tell
us why you believe you control the specimen prior to it be accessioned. In your response,
specifically address who has inventory risk prior to accession and what discretion you and
your suppliers have over pricing. Refer to ASC 606-10-55-39.
4.You previously stated that the “The third-party suppliers’ only responsibility is to provide
the specimen at the Company’s direction, and do not have any additional responsibilities
to fulfill the contract other than collecting the specimens in accordance with the
Company’s instruction and direction.” You also state that “At the time the specimen is
accessioned, we have satisfied our performance obligation.” If the third party suppliers are
responsible for both collecting and providing the specimen to the customer, please tell
us your performance obligations to the customers.
5.You also previously stated that "The Company has the right to direct when, how, and
where the specimens are sourced and ultimately delivered to the customer, as the
Company has the primary responsibility to fulfill the customer contract." Please further
clarify to us your basis as to how you have the right to direct when, how, and where the
specimens are sourced and ultimately delivered to the customer.
6.You previously stated that “The Company has full discretion in establishing pricing for
the specimen(s) and negotiates fees from its customers and bears credit risk in the sales
arrangements.”  On page 72 you state “We are flexible and allow our suppliers to work
with us using a number of revenue share constructs, including a fixed percent revenue

 FirstName LastNameChristopher Ianelli
 Comapany NameiSpecimen Inc.
 February 1, 2021 Page 3
 FirstName LastName
Christopher Ianelli
iSpecimen Inc.
February 1, 2021
Page 3
share arrangement (whereby we share a fixed percentage of the revenue back with them),
a fixed pricing schedule (whereby they set their pricing per specimen type), or on a
project-based pricing (whereby the supply site sets fees on a per project basis).” Please
advise as to how you determined you have full discretion in establishing the pricing for
specimens. Additionally, please further explain to us what you meant by you negotiate
fees from customers.
7.We note your statement that you believe that control transfers when a specimen has been
accessioned, since in accordance with ASC 610-10-25-27(c), it is at this point you have
created an asset without an alternative future use. Please further clarify for us how you
created the asset. Additionally please clarify for us how you determined that the asset has
no alternative future use.
8.Please tell us whether you believe revenue should be recognized at a point in time or over
time for your performance obligations. If at a point in time, provide us your analysis of
each of the indicators of the transfer of control in ASC 606-10-25-30 as of accession (i.e.,
at the point when you believe the customer has obtained control of a specimen).
            You may contact Aamira Chaudhry at (202) 551-3389 or Lyn Shenk at (202) 551-3380 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Katherine Bagley at (202) 551-2545 or Dietrich King at (202) 551-8071 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Tamar Donikyan

CORRESP
1
filename1.htm

iSpecimen Inc.

450 Bedford Street

Lexington, MA 02420

VIA EDGAR

January 20, 2021

U.S. Securities & Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, NE

Washington, D.C. 20549

Attn: Katherine Bagley

Re:    iSpecimen Inc.

Amendment No. 1 to Registration Statement
on Form S-1 Filed December 31, 2020

File No. 333-250198

Dear
Ms. Bagley:

iSpecimen,
Inc. (the “Company,” “we,” “our” or “us”)
hereby transmits the Company’s response to the comment letter received from the staff (the “Staff”) of
the U.S. Securities and Exchange Commission (the “Commission”), on January 15, 2021, regarding the Amendment
No. 1 to Registration Statement on Form S-1 filed with the Commission on December 31, 2020. For the Staff’s convenience,
we have repeated below the Staff’s comments in bold, and have followed each comment with the Company’s response.

Amendment
No. 1 to Registration Statement on Form S-1, filed December 31, 2020 Prospectus Summary

COVID-19 Impact, page 8

 1. We note your response to comment 3, and your amended disclosure on page 8. With a view to
understanding your business and supply chain, please amend your disclosure to briefly define "fully-disabled" and "partially-disabled,"
and the impact of each on your business.

Response:
 In response to the Staff’s comment, we have revised the disclosures on page 8.

Risk Factors

Risks related to our Business

"Challenges or unanticipated costs in establishing
. . .", page 20

 2. We note your response to comment 8, and your amended disclosure on page 20 that "[w]e
have entered into agreements with two non-exclusive distributors in the country of Japan and will continue to look for distributor
partnership opportunities covering other rest-of- world markets." It appears from your disclosure on page 81 that these agreements
are the Non-Exclusive Marketing, Sales & Distribution Agreements with BizCom Japan, Inc. and Cosmo Bio Co., Ltd. Please amend
your disclosure to include the minimum annual purchase order amount obligation under the terms of the agreement with BizCom Japan,
Inc. Please also file these agreements as exhibits to your registration statement, or tell us why you do not believe you are required
to do so. See Item 601(b)(10) of Regulation S-K.

Response: In
response to the Staff’s comment, we have amended the disclosures on page 81 to indicate that pursuant to the terms of
the Non-Exclusive Marketing, Sales & Distribution Agreement with BizCom Japan Inc. (“BizCom”), there
was no minimum annual purchase amount in the first year of the such agreement and that future minimum annual purchase amounts
will be set as mutually agreed to thereafter at the beginning of each contract year. Additionally, we respectfully submit
that these agreements are entered into in the ordinary course of our business and have not yet yielded any revenue (and we do
not expect them to yield any significant revenue in the near future). As such, these agreements are not material to our
business and therefore do not need to be filed as exhibits to the Registration Statement.

Business

Our Customers, page 75

 3. We note your response to comment 17, and your amended disclosure that "[w]e continue
to have and maintain site participation agreements with several provider partners which enable us to offer through our iSpecimen
Marketplace, various types of annotated hematologic products that are used in the research and development of regenerative medicine
therapies." In an appropriate place in your filing, please describe the terms of these site participation agreements, and
file the relevant agreements as exhibits to your registration statement, or tell us why you do not believe you are required to
do so. See Item 601(b)(10) of Regulation S-K.

Response: In
response to the Staff’s comment, we have revised the disclosures on pages 75 and 76 to remove references to these
specific agreements in the section entitled “Customer” because they are generally disclosed in the “Our
Supply Partners” section and these agreements are substantially the same as other site participation agreements.
Additionally, they are entered into in the ordinary course of our business and have not yielded any material revenue
to our business (a combined total of 1.8% in 2019 and 2.6% in the first nine months of 2020). As such, we respectfully submit
that such agreements are not material and do not need to be filed as exhibits to the Registration Statement.

Our Sales Pipeline, page 79

 4. We note your revised disclosure in response to our prior comment number 20. Please revise to
disclose how you define "open backlog."

Response:
In response to the Staff’s comment, we have revised the disclosures on pages 79 and 80.

Executive Compensation, page 95

 5. Please update your disclosure in this section to include information for your latest completed
fiscal year. See Item 402 of Regulation S-K.

Response:
In response to the Staff’s comment, we have revised the disclosures on page 95.

Notes to Financial Statements

Summary of Significant Accounting Policies

Revenue Recognition and Accounts Receivable, page
F-35, page F-35

 6. We note your response to our prior comment number 27. We also note your statement that "[t]he
hold was specifically related to circumstances whereby the supplier was not able to process the specimens due to COVID-19 shutdowns."
Please further clarify what you mean by "the supplier was not able to process the specimens." You also state "the
customer requested that the Company hold portions of its orders for a period of up to six months." Please clarify whether
you or the supplier was holding the specimens during the period of the related bill-and-hold.

Response:
There was an inadvertent error in the description of the parties in the bill-and-hold arrangement in our prior response
to comment number 27. The customer requested the supplier to hold portions of the order at the supplier location, as the customer
did not have available storage space in its facility to store the specimens before using the specimens for their intended use.

We noted that the updated
disclosure appropriately described the bill-and-hold arrangement, and as such no further edits are needed in the notes to the financial
statements.

 7. We note your response to our prior comment number 29. It appears that the terms "collected
and collection" are used in different contexts throughout the response and filing. Specifically, as it relates to the timing
of revenue recognition, please tell us and revise to disclose how you define "upon collection." We further note your
discussion of how you determined that the specimen has no alternative use and accordingly revenue should be recognized over time.
However, it is still not clear to us how you determined that control has transferred to the customer upon collection verses upon
shipment by you or receipt by the customer. Please tell us how you considered the guidance in ASC 606-1- 25-25. Please be detailed
and specific in your response.

Response: We
have updated the disclosures throughout the Registration Statement to use the term “accession” or
“accessioned” instead of “collect” or “collected”, where appropriate. Accessioned is when
a collected specimen has been registered and assigned to  the iSpecimen Marketplace to a particular customer order. In
addition, at that time, the specimen is segregated at the supplier for the customer. At the time we accession a specimen, we
recognize revenue. In response to the Staff’s comment, we have also revised our disclosures on pages 49, 60, F-11, and
F-34.

We considered the guidance in ASC 610-10-25-25
noting that our customers obtain control of a specimen when a specimen is accessioned because:

 · the specimen has been specifically identified based on the requested criteria and the specimen has been segregated for the
customer at the supplier (i.e. accessioned),

 · the customer has a contractual obligation to pay the Company upon the specimen being accessioned,

 · the specimen cannot be readily redirected or used to fulfill a different customer’s request, and

 · the customer has a contractual obligation to coordinate the shipment of the specimen.

At the time a specimen has been
accessioned, the customer obtains control of the specimen by having the ability to prevent other entities from directing the
use of, and therefore obtains the benefits from the accessioned specimen. Specimens are generally shipped as soon as possible
after they have been accessioned. In almost all instances, there is a very short period of time (i.e. the same day or days)
between the accession event and the shipment of the specimen to the customer. At the time the specimen is accessioned, we
have an enforceable right to payment and the customer is contractually obligated to remit payment.

The contractual Purchase Terms, between
the Company and a customer indicates, “All Specimens are shipped in accordance with Incoterms 2010 FCA. Shipments may be
insured for their value. Shipping and any insurance costs shall be the responsibility of Customer. Customer may supply its
own courier account number for direct billing of shipping and insurance costs or iSpecimen may bill Customer directly for shipping
and insurance costs.” For clarity, our shipping terms are FOB shipping point (i.e. from the supplier).

The shipping terms provide the customer
the ability to direct the use of and therefore obtain the benefits from the asset (a specimen). At the time the specimen is accessioned,
we have satisfied our performance obligation. In our previous response, we indicated that we incur shipping costs, however, we
would like to clarify that shipping costs are either paid directly by the customer or passed onto the customer per the terms above.

We believe that ASC 610-10-25-28 and
25-29 provides further guidance on the transfer of control of the specimen from the Company to its customers that supplement
the transfer of control guidance in ASC 610-10-25-25. Specifically, we believe that control transfers when a specimen has
been accessioned, since in accordance with ASC 610-10-25-27(c), it is at this point we have created an asset without an
alternative future use and  we have an enforceable right to payment for performance completed to date per our customer contracts.

We thank the Staff
for its review of the foregoing and the Registration Statement. If you have further comments, please feel free to contact to our
counsel, Tamar Donikyan, at tdonikyan@egsllp.com or by telephone at (212) 370-1300.

   Sincerely,

    /s/
                                         Christopher Ianelli

    Christopher
Ianelli, Chief Executive Officer

    iSpecimen
Inc.

United States securities and exchange commission logo
January 15, 2021
Christopher Ianelli
Chief Executive Officer
iSpecimen Inc.
450 Bedford Street
Lexington, MA 02420
Re:iSpecimen Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed December 31, 2020
File No. 333-250198
Dear Mr. Ianelli:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our December 14, 2020 letter.
Amendment No. 1 to Registration Statement on Form S-1, filed December 31, 2020
Prospectus Summary
COVID-19 Impact, page 8
1.We note your response to comment 3, and your amended disclosure on page 8.  With a
view to understanding your business and supply chain, please amend your disclosure to
briefly define "fully-disabled" and "partially-disabled," and the impact of each on your
business.

 FirstName LastNameChristopher Ianelli
 Comapany NameiSpecimen Inc.
 January 15, 2021 Page 2
 FirstName LastName
Christopher Ianelli
iSpecimen Inc.
January 15, 2021
Page 2
Risk Factors
Risks related to our Business
"Challenges or unanticipated costs in establishing . . .", page 20
2.We note your response to comment 8, and your amended disclosure on page 20 that "[w]e
have entered into agreements with two non-exclusive distributors in the country of Japan
and will continue to look for distributor partnership opportunities covering other rest-of-
world markets."  It appears from your disclosure on page 81 that these agreements are the
Non-Exclusive Marketing, Sales & Distribution Agreements with BizCom Japan, Inc. and
Cosmo Bio Co., Ltd.  Please amend your disclosure to include the minimum annual
purchase order amount obligation under the terms of the agreement with BizCom Japan,
Inc.  Please also file these agreements as exhibits to your registration statement, or tell us
why you do not believe you are required to do so.  See Item 601(b)(10) of Regulation S-K.
Business
Our Customers, page 75
3.We note your response to comment 17, and your amended disclosure that "[w]e continue
to have and maintain site participation agreements with several provider partners which
enable us to offer through our iSpecimen Marketplace, various types of annotated
hematologic products that are used in the research and development of regenerative
medicine therapies."  In an appropriate place in your filing, please describe the terms of
these site participation agreements, and file the relevant agreements as exhibits to your
registration statement, or tell us why you do not believe you are required to do so.  See
Item 601(b)(10) of Regulation S-K.
Our Sales Pipeline, page 79
4.We note your revised disclosure in response to our prior comment number 20. Please
revise to disclose how you define "open backlog."
Executive Compensation, page 95
5.Please update your disclosure in this section to include information for your latest
completed fiscal year.  See Item 402 of Regulation S-K.
Notes to Financial Statements
Summary of Significant Accounting Policies
Revenue Recognition and Accounts Receivable, page F-35, page F-35
6.We note your response to our prior comment number 27.  We also note your statement
that "[t]he hold was specifically related to circumstances whereby the supplier was not
able to process the specimens due to COVID-19 shutdowns."  Please further clarify what
you mean by "the supplier was not able to process the specimens."  You also state "the
customer requested that the Company hold portions of its orders for a period of up to six

 FirstName LastNameChristopher Ianelli
 Comapany NameiSpecimen Inc.
 January 15, 2021 Page 3
 FirstName LastName
Christopher Ianelli
iSpecimen Inc.
January 15, 2021
Page 3
months."  Please clarify whether you or the supplier was holding the specimens during the
period of the related bill-and-hold.
7.We note your response to our prior comment number 29.  It appears that the terms
"collected and collection" are used in different contexts throughout the response and
filing.  Specifically, as it relates to the timing of revenue recognition, please tell us and
revise to disclose how you define "upon collection."  We further note your discussion of
how you determined that the specimen has no alternative use and accordingly revenue
should be recognized over time.  However, it is still not clear to us how you determined
that control has transferred to the customer upon collection verses upon shipment by you
or receipt by the customer.  Please tell us how you considered the guidance in ASC 606-1-
25-25.  Please be detailed and specific in your response.
            You may contact Aamira Chaudhry at (202) 551-3389 or Lyn Shenk at (202) 551-3380 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Katherine Bagley at (202) 551-2545 or Dietrich King at (202) 551-8071 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Tamar Donikyan

CORRESP
1
filename1.htm

iSpecimen Inc.

450 Bedford Street

Lexington, MA 02420

VIA EDGAR

December  31, 2020

U.S. Securities & Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, NE

Washington, D.C. 20549

Attn: Katherine Bagley

 Re: iSpecimen Inc.

Registration Statement on Form S-1

Filed November 19, 2020

File No. 333-250198

Dear Ms. Bagley:

iSpecimen, Inc.
(the “Company,” “we,” “our” or “us”) hereby transmits
the Company’s response to the comment letter received from the staff (the “Staff”) of the U.S. Securities
and Exchange Commission (the “Commission”), on December 14, 2020, regarding the Registration Statement
on Form S-1 submitted to the Commission on November 19, 2020. For the Staff’s convenience, we have repeated below
the Staff’s comments in bold, and have followed each comment with the Company’s response.

Registration Statement on Form S-1
filed November 19, 2020

Prospectus Summary

The Opportunity, page 2

 1. Please briefly define "precision medicine market" and "regenerative medicine
market."

Response:
According to the US-FDA, most medical treatments are designed for the "average patient" as a one-size-fits-all-approach, which
may be successful for some patients but not for others. Precision Medicine, sometimes known as "personalized medicine"
is an innovative approach to tailoring disease prevention and treatment that takes into account differences in people's genes,
environments, and lifestyles. The goal of precision medicine is to target the right treatments to the right patients at the right
time. Personalized Medicine is generally comprised of two elements. One is the drug, biologic, or other therapeutic intervention,
and second is the diagnostic test.

The precision
medicine market therefore consists of numerous organizations operating throughout the world that are engaged in the research, development,
manufacturing, and commercialization of novel drugs, diagnostic tests, and technologies that boost the precision medicine workflow.

Regenerative
Medicine therapies (RMTs) are defined by the US-FDA as including cell therapies, therapeutic tissue engineering products,
human cell and tissue products, and combination products using any such therapies or products, except for those regulated
solely under section 361 of the Public Health Service Act (42 U.S.C. 264) and Title 21 of the Code of Federal Regulations
Part 1271 (21 CFR Part 1271). Human gene therapy products, including genetically modified cells that lead to a sustained
effect on cells or tissues, and xenogeneic cell products may meet the definition of an RMT. The FDA interprets cell therapies
to include both allogeneic and autologous cell therapies. Similarly, the Alliance for Regenerative Medicine describes
regenerative medicine as including gene therapies, cell therapies, and tissue-engineered products intended to augment,
repair, replace, or regenerate organs, tissues, cells, genes, and metabolic processes in the body. The regenerative medicine
market therefore consists of numerous organizations operating throughout the world that are engaged in the research,
development, manufacturing, and commercialization of cell and immunotherapies, genetically modified cells, therapeutic tissue
engineered products, human cell and tissue products, and combination products using any such therapies or products. In
response to the Staff’s comment, we have revised the disclosures on pages 2 and 65.

Our Competitive Advantages, page 5

 2. We note your disclosure that "[w]hile [you] believe [y]our iSpecimen Marketplace is driving
these benefits now, they will become even more apparent in the future when the iSpecimen Marketplace achieves scale." In an
appropriate place in your filing, please clarify when you expect to achieve scale, and the steps you must take to do so. In addition,
to balance your disclosure, please disclose here that to date you have been unable to operate the marketplace profitably. In doing
so, please include net loss information for recent periods.

    Ms. Bagley

December 31, 2020

Page 2 of 14

Response: In response to the
Staff’s comment, we have revised the disclosures on pages  7 and 78 .

COVID-19 Impact, page 7

 3. Here and on page 46 of your filing, please quantify the impact of the slowdown in healthcare
provider research on your purchase orders, and on your total revenue. Please also quantify the extent to which you have recovered
from the slowdown. In this regard, we note your disclosure on page 46 that "[a]s of September 30, 2020, most of
our supply organizations had resumed research operations but generally in a more limited capacity than before the pandemic began."
In addition, please disclose that in May 2020 you applied for and received a loan for $783,008 from the Paycheck Protection
Program under the CARES Act.

Response: In response to the
Staff’s comment, we have revised the disclosures on pages 8, 9, 15, 48, 87 and 88 .

Risk Factors

Risks related to our Business

"We have a relatively short operating history . .
.", page 12

 4. Please briefly describe the "number of factors" that affect your ability to accurately
forecast your future results.

Response: In response to the Staff’s comment,
we have revised the disclosures on page 14 .

"Sustainable future revenue growth is dependent upon
. . .", page 15

 5. Please quantify the "relatively significant amount of resources" you are spending
on the development of the iSpecimen Marketplace platform, or tell us why you believe you are not required to do so.

Response: In response to the Staff’s comment,
we have revised the disclosures on page 17 .

"We rely upon our technology solution for the operation
of our business . . .", page 15

 6. Please quantify, if material, the "stall" in your revenue growth rate in mid-2018
to mid- 2019, related to your critical software update.

Response: In response to the Staff’s
comment, we have revised the disclosures on page  16.

    Ms. Bagley

December 31, 2020

Page 3 of 14

"We rely upon third-party technology licenses .
. .", page 16

 7. You disclose that you rely on third parties for "certain technology." Please briefly
describe the types of technology you license from third parties, describe the material terms of your licensing agreements with
third parties, and file any relevant licensing agreements as exhibits to your filing. See Item 601(b)(10) of Regulation S-K.
Alternatively, please tell us why you do not believe you are required to file any applicable agreements as exhibits to your registration
statement.

Response: We respectfully submit that
we do not believe we currently rely on any technology we license from third parties because we believe we can replace any of
the licensed technology from a another third party with similar terms. As such, we do not believe any of these agreements are
material to our business and have not included any such agreements as exhibits to our registration statement. In response to
the Staff’s comment, we have revised the disclosures on pages 6, 17 and 72.

"Challenges or unanticipated costs in establishing
. . .", page 18

 8. Please clarify when you expect to begin seeking distributors in the life sciences industry to
market and sell your products and services outside of the United States.

Response: In 2020, we started the
process of identifying potential distributors to market and sell our products and services to key jurisdictions outside the
United States. iSpecimen has entered into agreements with two non-exclusive distributors in the country of Japan and will
continue to look for distributor partnership opportunities covering other rest-of-world markets. In response to the
Staff’s comment, we have revised the disclosures on page 20.

"We do not control the end-to-end quality of specimens
. . .", page 21

 9. Please quantify the cost of the refunds and replacements referenced in this risk factor related
to the specimens that did not meet specifications in 2019, if material.

Response: We respectfully submit that the
costs of the refunds and replacements of the specimens is approximately $1,000 for fiscal year 2019. In response to the Staff’s
comment, we have revised the disclosures on page 23.

Use of Proceeds, page 37

 10. We note your disclosure that you will use a portion of the proceeds to repay accrued and unpaid
interest of the Bridge Notes. Because you will use a portion of the proceeds to repay debt, please disclose the interest rate and
maturity of such indebtedness in this section. Please also amend your "Use of Proceeds" disclosure in your Prospectus
Summary to disclose that you will use a portion of the proceeds to repay this debt. Further, because a portion of these Bridge
Notes appears to have been issued within one year, please describe the use of the proceeds of such indebtedness other than short-term
borrowings used for working capital. See Instruction 4 to Item 504 of Regulation S-K.

Response: In response to the Staff’s
comment, we have revised the disclosures on pages 11 and 39. Additionally, we respectfully submit that the proceeds from
the Bridge Notes were used exclusively for working capital needs.

    Ms. Bagley

December 31, 2020

Page 4 of 14

Management's Discussion and Analysis of Financial Condition
and Results of Operations Financial Operations Overview and Analysis for the Three and Nine Months Ended September 30, 2020
and 2019 . . ., page 48

 11. Throughout your discussion of your results of operations for the financial periods presented,
where you discuss multiple factors underlying changes in line items, please quantify the contribution of each factor. For example,
you disclose that "[f]or the three months ended September 30, 2020, revenue increased by approximately $1,557,000 or
225%, as compared with the three months ended September 30, 2019 primarily due to an expansion of our sales team in the second
half of 2019 and new demand for specimens from patients with known COVID-19 test results, especially remnant specimens." Please
make conforming changes throughout your results of operations disclosure.

Response: In response to the Staff’s
comment, we have revised the disclosures on pages 50 to 55.

Business, page 61

 12. In an appropriate place in your filing, please clarify whether you require fees for use of your
platform, including the marketing, sales, contracting, and compliance functions you perform for researchers and suppliers.

Response: In response to the Staff’s
comment, we have revised the disclosures on page 72.

The Challenges, page 62

 13. We note your reference to a survey of certain researchers you conducted in 2019. Pleas	provide
us with context and additional detail about the parameters of this survey, including a discussion of the number of researchers
you surveyed, the number that responded, the types of questions that were asked, and how your survey results support your statement
that "more than 80% of researchers limit the scope of their research because of the difficulty of finding adequate quantity
and/or quality of specimens for their research."

Response: In the first quarter of 2019, we emailed approximately 3,500 researchers who were in the iSpecimen marketing database requesting they
respond to a survey about biospecimen procurement. These names were generated over time from inbound inquiries and leads, industry conferences,
and marketing engagements such as webinar participation and content downloads. This group included life science researchers and biospecimen
procurement personnel from pharma/biotech, in vitro diagnostics, clinical research organizations, and university/academia. Approximately
36 researchers responded anonymously to the survey via Surveymonkey.com. This was largely a U.S. audience given our marketing database.
There were approximately 15 questions that covered the type of organization they were from, the research area, how they were involved
in the biospecimen procurement process, their challenges, their overall biospecimen procurement experiences, and their overall knowledge/experience
with the iSpecimen Marketplace.

In one question, the researchers were asked, “How often do you limit the scope of your work due
to the shortage of quality biospecimens?” 82% of the respondents said “sometimes,” “often,” or “always.”

Technology Development, page 67

 14. Please amend your disclosure to describe your plans for technology development in the near future,
including when you expect to implement such plans. In this regard, we note your disclosure on page 19 that "[c]urrently,
[your platform] does not fully support self-service eCommerce because key capabilities required to satisfy these transactions across
all of [y]our product lines, such as a pricing engine and patient-level search, have yet to be incorporated." Please clarify
when you expect the pricing engine, patient-level search, and other key capabilities to be incorporated into your platform.

    Ms. Bagley

December 31, 2020

Page 5 of 14

Response: In response to the Staff’s
comment, we have revised the disclosures on pages 5, 69 and 70.

Our Products and Services, page 68

 15. Where you describe the product types you use to track and manage your business, please describe
how the demand for and supply of each impacts your business and operations. In this regard, we note your disclosure on page 50
that "remnant specimens generally have lower procurement costs than research use only specimens." Please discuss relevant
differences in costs to acquire and distribute each product type, ease of procuring inventory of each, and any other differences
that materially or could materially affect your operations.

Response: In response to the Staff’s
comment, we have revised the disclosures on pages 72 to 74.

Our Supply Partners, page 69

 16. Please disclose the names of the principal suppliers discussed in this section, or tell us why
you believe you are not required to do so. See Item 101(h)(4)(v) of Regulation S-K.

Response: We respectfully
submit that such information is not material to an understanding of our business because our supplier concentration changes yearly
and we do not believe any one supplier has played a critical role to the Company’s business operation.

Our Customers, page 70

 17. We note your disclosure that, "in 2019, [you] entered the new and rapidly growing regenerative
medicine segment." To provide context for investors regarding this segment and your participation in this segment, please
disclose the measure by which you determined this segment is "rapidly growing," and clarify how you have entered into
this segment, including the products you provide, the number of distribution customers, and/or the percentage of your revenue attributable
to this segment in the relevant periods presented.

Response: According
to a market research report published by Fortune Business Insight, the global regenerative medicine market was valued at
US$ 23.8 billion in 2018 and is expected to reach US$ 152 billion by the end of 2026 thereby exhibiting an estimated CAGR of 26%.
Moreover, according to the Alliance for Regenerative Medicine: 1. Global financing for the regenerative medicine sector
set an annual record of $15.9 billion through just the first three quarters of 2020. Despite the COVID-19 pandemic, financing
for the cell, gene, and tissue-based therapies sector surpassed the previous record of $13.5 billion set during full year 2018;
and 2. As of Q3-2020, there are now 1,026 regenerative medicine and advanced therapy developers active worldwide with 1,109 clinical
trials ongoing worldwide. Hence, the “rapid growth” of the regenerative medicine market is characterized by this double-digit
annual revenue growth rate combined with record global financing levels and increasing number of organizations conducting clinical
trials.

We have entered into site participation agreements with several
provider partners which enable us to offer through our Mar

United States securities and exchange commission logo
December 14, 2020
Christopher Ianelli
Chief Executive Officer
iSpecimen Inc.
450 Bedford Street
Lexington, MA 02420
Re:iSpecimen Inc.
Registration Statement on Form S-1
Filed November 19, 2020
File No. 333-250198
Dear Mr. Ianelli:
            We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.
Registration Statement on Form S-1 filed November 19, 2020
Prospectus Summary
The Opportunity, page 2
1.Please briefly define "precision medicine market" and "regenerative medicine market."
Our Competitive Advantages, page 5
2.We note your disclosure that "[w]hile [you] believe [y]our iSpecimen Marketplace is
driving these benefits now, they will become even more apparent in the future when the
iSpecimen Marketplace achieves scale."  In an appropriate place in your filing, please
clarify when you expect to achieve scale, and the steps you must take to do so. In addition,
to balance your disclosure, please disclose here that to date you have been unable to
operate the marketplace profitably.  In doing so, please include net loss information for

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 Comapany NameiSpecimen Inc.
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Christopher Ianelli
iSpecimen Inc.
December 14, 2020
Page 2
recent periods.
COVID-19 Impact, page 7
3.Here and on page 46 of your filing, please quantify the impact of the slowdown in
healthcare provider research on your purchase orders, and on your total revenue.  Please
also quantify the extent to which you have recovered from the slowdown.  In this regard,
we note your disclosure on page 46 that "[a]s of September 30, 2020, most of our supply
organizations had resumed research operations but generally in a more limited capacity
than before the pandemic began."  In addition, please disclose that in May 2020
you applied for and received a loan for $783,008 from the Paycheck Protection Program
under the CARES Act.
Risk Factors
Risks related to our Business
"We have a relatively short operating history . . .", page 12
4.Please briefly describe the "number of factors" that affect your ability to accurately
forecast your future results.
"Sustainable future revenue growth is dependent upon . . .", page 15
5.Please quantify the "relatively significant amount of resources" you are spending on the
development of the iSpecimen Marketplace platform, or tell us why you believe you are
not required to do so.
"We rely upon our technology solution for the operation of our business . . .", page 15
6.Please quantify, if material, the "stall" in your revenue growth rate in mid-2018 to mid-
2019, related to your critical software update.
"We rely upon third-party technology licenses . . .", page 16
7.You disclose that you rely on third parties for "certain technology."  Please briefly
describe the types of technology you license from third parties, describe the material terms
of your licensing agreements with third parties, and file any relevant licensing agreements
as exhibits to your filing.  See Item 601(b)(10) of Regulation S-K.  Alternatively, please
tell us why you do not believe you are required to file any applicable agreements as
exhibits to your registration statement.
"Challenges or unanticipated costs in establishing . . .", page 18
8.Please clarify when you expect to begin seeking distributors in the life sciences industry to
market and sell your products and services outside of the United States.

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Christopher Ianelli
iSpecimen Inc.
December 14, 2020
Page 3
"We do not control the end-to-end quality of specimens . . .", page 21
9.Please quantify the cost of the refunds and replacements referenced in this risk
factor related to the specimens that did not meet specifications in 2019, if material.
Use of Proceeds, page 37
10.We note your disclosure that you will use a portion of the proceeds to repay accrued and
unpaid interest of the Bridge Notes.  Because you will use a portion of the proceeds to
repay debt, please disclose the interest rate and maturity of such indebtedness in this
section.  Please also amend your "Use of Proceeds" disclosure in your Prospectus
Summary to disclose that you will use a portion of the proceeds to repay this debt.
Further, because a portion of these Bridge Notes appears to have been issued within one
year, please describe the use of the proceeds of such indebtedness other than short-term
borrowings used for working capital.  See Instruction 4 to Item 504 of Regulation S-K.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Financial Operations Overview and Analysis for the Three and Nine Months Ended September
30, 2020 and 2019 . . ., page 48
11.Throughout your discussion of your results of operations for the financial periods
presented, where you discuss multiple factors underlying changes in line items, please
quantify the contribution of each factor.  For example, you disclose that "[f]or the
three months ended September 30, 2020, revenue increased by approximately $1,557,000
or 225%, as compared with the three months ended September 30, 2019 primarily due to
an expansion of our sales team in the second half of 2019 and new demand for specimens
from patients with known COVID-19 test results, especially remnant specimens."  Please
make conforming changes throughout your results of operations disclosure.
Business, page 61
12.In an appropriate place in your filing, please clarify whether you require fees for use of
your platform, including the marketing, sales, contracting, and compliance functions you
perform for researchers and suppliers.
The Challenges, page 62
13.We note your reference to a survey of certain researchers you conducted in 2019.  Please
provide us with context and additional detail about the parameters of this survey,
including a discussion of the number of researchers you surveyed, the number that
responded, the types of questions that were asked, and how your survey results
support your statement that "more than 80% of researchers limit the scope of their
research because of the difficulty of finding adequate quantity and/or quality of specimens
for their research."

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Christopher Ianelli
iSpecimen Inc.
December 14, 2020
Page 4
Technology Development, page 67
14.Please amend your disclosure to describe your plans for technology development in the
near future, including when you expect to implement such plans.  In this regard, we note
your disclosure on page 19 that "[c]urrently, [your platform] does not fully support self-
service eCommerce because key capabilities required to satisfy these transactions across
all of [y]our product lines, such as a pricing engine and patient-level search, have yet to be
incorporated."  Please clarify when you expect the pricing engine, patient-level search,
and other key capabilities to be incorporated into your platform.
Our Products and Services, page 68
15.Where you describe the product types you use to track and manage your business, please
describe how the demand for and supply of each impacts your business and operations.  In
this regard, we note your disclosure on page 50 that "remnant specimens generally have
lower procurement costs than research use only specimens."  Please discuss relevant
differences in costs to acquire and distribute each product type, ease of procuring
inventory of each, and any other differences that materially or could materially affect your
operations.
Our Supply Partners, page 69
16.Please disclose the names of the principal suppliers discussed in this section, or tell us
why you believe you are not required to do so.  See Item 101(h)(4)(v) of Regulation S-K.
Our Customers, page 70
17.We note your disclosure that, "in 2019, [you] entered the new and rapidly growing
regenerative medicine segment."  To provide context for investors regarding this segment
and your participation in this segment, please disclose the measure by which you
determined this segment is "rapidly growing," and clarify how you have entered into this
segment, including the products you provide, the number of distribution customers, and/or
the percentage of your revenue attributable to this segment in the relevant periods
presented.
18.You disclose that "in 2019, [you] significantly expanded [y]our client base outside the
Americas in large part due to one large international project."  Please disclose whether
you expect to continue to engage with a client base outside of the Americas upon the
termination of this large international project, and if you expect future projects to have the
same "significance."
Our Competitors, page 72
19.You disclose that "[you] know of no other online human biospecimen marketplaces that
provide instant access and searchability of specimens across a network of healthcare
providers."  We note there appear to be other searchable online marketplaces, including

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iSpecimen Inc.
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but not limited to Discovery Life Sciences, Science Exchange, and StemExpress.  Please
tell us why you believe these or other online providers are not online human biospecimen
marketplaces that operate in a manner similar to your business.  Alternatively, please
amend your disclosure to identify other online biospecimen marketplaces as your
competitors, if applicable.
Our Sales Pipeline, page 73
20.You state that the purchase order stage begins with the receipt of the purchase order (or
equivalent document) and ends as the specimen request is fulfilled or lost.  Please explain
what you mean by the term lost.  In your sales pipeline stage tables, the amount of
purchase orders generally exceeds revenue by significant amounts.  Please explain the
reasons these figures differ.  To the extent they differ due to purchase orders not being
firm and subsequently being cancelled or otherwise not fulfilled by you, please revise
your disclosure to explain the extent to which your purchase orders are not firm.
Regulations
21 CFR Part 11 Electronic Records; Electronic Signatures, page 79
21.Considering your disclosures that "the iSpecimen Marketplace has not been certified or
audited for 21 CFR Part 11 compliance," and you " do not require the originating systems
from whom [you] receive data to be 21 CFR Part 11 compliant," please disclose the
potential consequences to you when clients may submit data to the FDA that was
received, stored, and transmitted in your systems, if material.  As a related matter, please
disclose the potential consequences to you if you fail to properly audit and identify gaps in
the informed consent forms used to collect samples and data as part of your offerings
pursuant to 21 CFR Part 50, and if there are gaps in your IRB composition and operations
making them incompatible with 21 CFR Part 56.
International Regulatory Environment, page 80
22.We note your disclosure that you "generally rely upon [y]our contractual terms with [EU
supply partners] as a means for obligating them to provide [you] data in accordance with
the GDPR regulations."  Please briefly describe any other audits or practices upon which
you rely to ensure your operations comply with GDPR regulations.
Other Applicable Laws, page 80
23.You disclose that you are subject to state and local laws and regulations for the disposal
and handling of medical waste and biohazardous material.  If material, pease disclose the
costs of compliance with these disposal laws, and discuss whether any of these laws have
environmental implications.  See Item 101(h)(4)(xi) of Regulation S-K.
Anti-Takeover Effects of Certain Provisions of Our Bylaws, page 102
24.Please amend your filing to add risk factor disclosure describing the risks related to the

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anti-takeover effects described in this section of your registration statement.
Registration Rights, page 102
25.We note your disclosure that certain shares are "registered for resale as part of the
registration statement of which this prospectus forms a part."  However, it does not appear
that you are registering a resale component of this offering.  Please amend your disclosure
to clarify, if true, that these registration rights are related to a future registration statement,
or amend your filing to register the resale shares and to provide the disclosure required by
Item 507 of Regulation S-K.
Condensed Balance Sheets, page F-27
26.We note you recorded deferred revenue of approximately $582,000.  Please tell us and
revise to disclose how the deferred revenue arose.
Notes to Financial Statements
Summary of Significant Accounting Policies
Revenue Recognition and Accounts Receivable, page F-35
27.We note that you may enter into bill-and-hold arrangements with certain customers.
Please tell us, on average, how long you hold the products for the customers.
Additionally, please quantify the amount of revenue recognized under bill and hold
arrangements during each period presented.
28.We note that you have concluded that you are the principle.  You further state that you
control the collection of the specimens being provided prior to transferring control to the
customer.  However, in your footnote on inventory you also state that “The Company
takes possession of specimens in limited circumstances.”  Please tell us in further detail
how you determined that you control the specimen before it is transferred to a customer.
Additionally, please clarify how, when and by whom the specimens are transferred to the
customer.
29.You state the performance obligation is satisfied when the related specimens are collected
(rather than upon shipment to the customer).  Please tell us your basis under ASC 606 for
concluding that control of the specimen has transferred to the customer upon collection
rather than upon shipment by you or receipt by the customer.
General
30.Please provide us with supplemental copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
have presented or expect to present to potential investors in reliance on Section 5(d) or
Rule 163B of the Securities Act, whether or not you retained, or intend to retain, copies of
those communications.  Please contact the staff member associated with the review of this
filing to discuss how to submit the materials, if any, to us for our review.

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            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.