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.
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

               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.


                          Division of Corporation Finance

                          Office of Life Sciences
       cc:                                              Amy E. Culbert, Esq.