United States securities and exchange commission logo October 17, 2022 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 October 11, 2022 File No. 333-267817 Dear Sean E. 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 Christine Westbrook at 202-551-5019 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Emily Humbert, Esq.