United States securities and exchange commission logo December 27, 2022 Michael McGarrity Chief Executive Officer MDxHealth SA CAP Business Center Zone Industrielle des Hauts-Sarts 4040 Herstal, Belgium Re: MDxHealth SA Registration Statement on Form S-1 Filed December 19, 2022 File No. 333-268885 Dear Michael McGarrity: 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 Jordan Nimitz at 202-551-5831 with any questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services