664 Cruiser Lane
Belgrade, Montana 59714
(406) 388-0480

 

May 14, 2021

 

VIA EDGAR

 

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, NE

Washington, DC 20549

Attention: Irene Paik

 

  Re: Xtant Medical Holdings, Inc.
    Registration Statement on Form S-3
    Filed May 11, 2021
    File No. 333-255988
    Request for Acceleration

 

Ladies and Gentlemen:

 

Pursuant to Rule 461 of the Securities Act of 1933, as amended, Xtant Medical Holdings, Inc. (the “Company”) hereby respectfully requests that the effective date of the above-referenced registration statement be accelerated so that it will be declared effective at 4:30 p.m., Eastern Time, on May 18, 2021, or as soon thereafter as is practicable.

 

The Company requests that it be notified of such effectiveness by a telephone call to Emily Humbert of Fox Rothschild LLP at (612) 607-7076.

 

Thank you for your assistance in this matter. Should you have any questions, please call Ms. Humbert.

 

    Very truly yours,
     
    XTANT MEDICAL HOLDINGS, INC.
     
    /s/ Sean E. Browne
    Sean E. Browne
    President and Chief Executive Officer
     
cc: Amy E. Culbert, Esq.  
  Emily Humbert, Esq.