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                          September 15, 2020

       Sean E. Browne
       Chief Executive Officer
       Xtant Medical Holdings, Inc.
       664 Cruiser Lane
       Belgrade, MT 59714

                                                        Re: Xtant Medical
Holdings, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed September 11,
2020
                                                            File No. 333-248766

       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 Ada D.
Sarmento at 202-551-3798 with any questions.




                          Sincerely,


                          Division of Corporation Finance

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