September 13, 2018

McCord Christensen
Chief Executive Officer
PetIQ, Inc.
923 S. Bridgeway Pl.
Eagle, ID 83616

       Re: PetIQ, Inc.
           Registration Statement on Form S-3
           Filed September 4, 2018
           File No. 333-227186

Dear Mr. Christensen:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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 this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Form S-3 filed September 4, 2018

Description of Stock Purchase Contracts and Stock Purchase Units, page 15

1.     We note your disclosure that you may issue purchase contracts for the
purchase or sale of
       equity securities that may consist of obligations of third parties.
Please advise us how you
       anticipate conducting such offerings under the registration and
disclosure requirements of
       the Securities Act. For example, please advise us of the disclosure you
will provide in the
       applicable prospectus supplement or other offering materials, including,
as necessary,any
       required financial statement and non-financial statement disclosure
about the issuer of
 McCord Christensen
PetIQ, Inc.
September 13, 2018
Page 2
         such securities. For guidance, please refer to the Morgan Stanley &
Co., Inc. no action
         letter (June 24, 1996) and Securities Act Sections Compliance and
Disclosure
         Interpretation 203.03.
2.       It is not clear how the purchase contracts you propose to issue should
be characterized for
         purposes of the federal securities laws. For example, the disclosure
in the filing indicates
         that these contracts may obligate you to sell to holders of these
contracts and for holders
         of these contracts to purchase securities at a specified purchase
price. The disclosure in the
         filing also indicates that these contracts may require you to make
periodic payments to the
         holders of the contracts or for holders of these contracts to make
periodic payments to
         you. Finally, the disclosure in the filing indicates that these
contracts may require the
         holders of the contracts to secure their obligations in a specified
manner. Based on this
         disclosure it appears that these contracts may have characteristics
associated with
         forwards, options and security-based swaps. Please provide us with
your legal analysis as
         to how these contracts should be appropriately characterized under
Section 2(a)(1) of the
         Securities Act of 1933.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Jonathan Burr at 202-551-5833 or James Lopez at
202-551-3536 with
any questions.



                                                                Sincerely,
FirstName LastNameMcCord Christensen
                                                                Division of
Corporation Finance
Comapany NamePetIQ, Inc.
                                                                Office of
Beverages, Apparel and
September 13, 2018 Page 2                                       Mining
FirstName LastName