December 11, 2018

Noreen Griffin
Chief Executive Officer and Director
Immune Therapeutics, Inc.
37 North Orange Ave, Suite 607
Orlando, FL 32801

       Re: Immune Therapeutics, Inc.
           Amendment No. 1 to Preliminary Proxy Statement
           on Schedule 14A
           Filed November 29, 2018
           File No. 000-54933

Dear Ms. Griffin:

       We have reviewed your filing 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 these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

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

PRER14A Filed November 29, 2018

General

1.    Please note the preliminary revised proxy statement filed in response to
these comments
      should include the entire proxy statement, as opposed to just the amended
items.
2.    Please disclose the reasons for the authorization and designation of
preferred stock,
      reverse stock split, and name change. Please see Items 11(d), 12(c), and
19 of Schedule
      14A.
3.    Since you are proposing to authorize additional shares of preferred
stock, please disclose
      whether you have any plans, arrangements, understandings, etc. to issue
any of
      the preferred stock. If you do have a intent to issue any of the
preferred stock, please
      consider whether you are required to provide financial statements and
other information
      described in Item 13 of Schedule 14A. Either include this information in
your proxy
 Noreen Griffin
Immune Therapeutics, Inc.
December 11, 2018
Page 2
      statement or provide us with an analysis explaining why this information
is not required.
       See Item 11(e) and Instruction 1 to Item 13 of Schedule 14A.
4.    Please clarify whether you will reduce the number of authorized shares of
common stock
      in proportion to the reverse stock split. If you do not intend to reduce
the number of
      authorized shares, please disclose the increase in authorized shares
available for issuance
      resulting from a 800-to-1 reverse stock spilt and from a 1,000-to-1
reverse stock split and
      disclose any plans to issues these newly available shares. If you do not
have plans to issue
      the newly available shares, revise your disclosure to clarify that you
currently have no
      such plans.
        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.

       You may contact Jeffrey Gabor at 202-551-2544 or Suzanne Hayes at
202-551-3675 with
any questions.



                                                            Sincerely,
FirstName LastNameNoreen Griffin
                                                            Division of
Corporation Finance
Comapany NameImmune Therapeutics, Inc.
                                                            Office of
Healthcare & Insurance
December 11, 2018 Page 2
cc:       Arden E. Anderson, Esq.
FirstName LastName