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                    May 28, 2020

       Stuart Gleichenhaus
       Interim Chief Financial Officer
       Covetrus, Inc.
       7 Custom House Street
       Portland, ME 04101

                                                        Re: Covetrus, Inc.
                                                            Form 10-K for the
Year Ended December 31, 2019
                                                            Filed March 3, 2020
                                                            File No. 001-38794

       Dear Mr. Gleichenhaus:

              We have completed our review of your filing. 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.




                    Sincerely,


                    Division of Corporation Finance

                    Office of Trade & Services