664 Cruiser Lane

Belgrade, Montana 59714

(406) 388-0480

 

December 22, 2020

 

VIA EDGAR

 

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, NE

Washington, DC 20549

Attention: Chris Edwards

 

	Re:	Xtant Medical Holdings, Inc.
		Registration Statement on Form S-1
		Filed December 18, 2020
		File No. 333-251515
		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 December 23, 2020, 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.