United States securities and exchange commission logo May 26, 2020 Bosco Chiu Chief Financial Officer HERBALIFE NUTRITION LTD. P.O. Box 309GT Ugland House, South Church Street Grand Cayman, Cayman Islands KY1-1106 Re: HERBALIFE NUTRITION LTD. Form 10-K for the Fiscal Year Ended December 31, 2019 Filed February 18, 2020 File No. 1-32381 Dear Mr. Chiu: 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 cc: Henry Wang, General Counsel