United States securities and exchange commission logo April 9, 2021 Sean E. Browne President and Chief Executive Officer Xtant Medical Holdings, Inc. 664 Cruiser Lane Belgrade, MT 59714 Re: Xtant Medical Holdings, Inc. Registration Statement on Form S-3 Filed April 6, 2021 File No. 333-255074 Dear Mr. Browne: 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 Deanna Virginio at 202-551-4530 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Amy E. Culbert, Esq.