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                             August 19, 2022

       Sharon L. Hollis
       Chief Executive Officer
       InnovaQor, Inc.
       400 S. Australian Avenue, Suite 800
       West Palm Beach, FL 33401

                                                        Re: InnovaQor, Inc.
                                                            Registration
Statement on Form 10-12G
                                                            Filed July 29, 2022
                                                            File No. 000-33191

       Dear Ms. Hollis:

              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.

       Registration Statement on Form 10 filed July 29, 2022

       Item 2. Financial Information
       Liquidity, Capital Resources and Acquisition, page 30

   1.                                                   Please revise to
disclose the minimum period of time that you will be able to
                                                        conduct planned
operations using currently available capital resources. Refer to Item
                                                        303(b)(1) of Regulation
S-K.
       Item 6. Executive Compensation.
       Consulting Agreement, page 38

   2.                                                   You disclose that the
company entered into a consulting agreement with Mr. Dab for one
                                                        year effective June 1,
2021. Identify the company affiliated with Mr. Dab and disclose
                                                        whether the agreement
has expired. Clarify any obligations that remain under the
                                                        agreement and the total
amount that was paid to Mr. Dab   s company under the agreement.
 Sharon L. Hollis
InnovaQor, Inc.
August 19, 2022
Page 2
General

3.     Please amend your filing to update your interim financial statements
through the quarter
       ended June 30, 2022.
4.     Additionally, please revise your Management's Discussion and Analysis on
page 32 and
       interim period disclosures elsewhere in the filing to pertain to the
quarter ended June 30,
       2022.
        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 Joseph Kempf, Senior Staff Accountant, at (202)
551-3352 or Kathryn
Jacobson, Senior Staff Accountant, at (202) 551-3365 if you have questions
regarding comments
on the financial statements and related matters. Please contact Olivia Bobes,
Law Clerk, at (202)
551-7361 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other
questions.



                                                             Sincerely,
FirstName LastNameSharon L. Hollis
                                                             Division of
Corporation Finance
Comapany NameInnovaQor, Inc.
                                                             Office of
Technology
August 19, 2022 Page 2
cc:       Thomas Cookson
FirstName LastName