July 10, 2019

N. Scott Fine
Chief Executive Officer
CTD Holdings, Inc.
6714 NW 16th Street, Suite B
Gainesville, FL 32563

       Re: CTD Holdings, Inc.
           Registration Statement on Form S-1
           Filed June 27, 2019
           File No. 333-232408

Dear Mr. Fine:

       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 Sherry Haywood at (202) 551-3345 with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Manufacturing and
                                                            Construction