March 29, 2019 Terren S. Peizer Chief Executive Officer Catasys, Inc. 11601 Wilshire Boulevard, Suite 1100 Los Angeles, California 90025 Re: Catasys, Inc. Registration Statement on Form S-3 Filed March 22, 2019 File No. 333-230475 Dear Mr. Peizer: 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 Ronald (Ron) E. Alper at 202-551-3329 with any questions. Sincerely, Division of Corporation Finance Office of Beverages, Apparel and Mining cc: Lili Taheri