CORRESP 1 filename1.htm



664 Cruiser Lane

Belgrade, Montana 59714

(406) 388-0480


December 22, 2020




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,
  /s/ Sean E. Browne
  Sean E. Browne
  President and Chief Executive Officer


cc: Amy E. Culbert, Esq.
  Emily Humbert, Esq.