United States securities and exchange commission logo

                              January 12, 2021

       Daniel J. Starck
       Chief Executive Officer
       Apria, Inc.
       7353 Company Drive
       Indianapolis, Indiana 46237

                                                        Re: Apria, Inc.
                                                            Amendment No. 3 to
Draft Registration Statement on Form S-1
                                                            Submitted January
4, 2021
                                                            CIK No. 0001735803

       Dear Mr. Starck:

              We have reviewed your amended draft registration statement and
have the following
       comment. In our comment we may ask you to provide us with information so
we may better
       understand your disclosure.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comment applies to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your

             After reviewing the information you provide in response to this
comment and your
       amended draft registration statement or filed registration statement, we
may have additional

       Amendment No. 3 to Draft Registration Statement on Form S-1

       Use of Proceeds, page 58

   1.                                                   We note that with this
amendment the company will offer shares for sale, in addition to
                                                        the shares to be sold
by current shareholders. As it appears there is no specific plan for
                                                        your use of proceeds,
please revise the disclosure here to discuss the principal reasons for
                                                        the offering and add a
risk factor concerning the lack of a specific plan. Please refer to
                                                        Item 504 of Regulation
              You may contact Jeanne Bennett at 202-551-3606 or Mary Mast at
202-551-3613 if you
       have questions regarding comments on the financial statements and
related matters. Please
       contact Abby Adams at 202-551-6902 or Laura Crotty at 202-551-7614 with
any other questions.
 Daniel J. Starck
Apria, Inc.
January 12, 2021
Page 2

FirstName LastNameDaniel J. Starck
                                     Division of Corporation Finance
Comapany NameApria, Inc.
                                     Office of Life Sciences
January 12, 2021 Page 2
cc:       Edgar Lewandowski, Esq.
FirstName LastName