Piper Sandler & Co.

800 Nicollet Mall

Minneapolis, Minnesota 55402

Cantor Fitzgerald & Co.

499 Park Avenue

New York, New York 10022

January 25, 2021

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, N.E.

Washington, D.C. 20549-6010

Attention:    David Gessert

 

Re:	Surgalign Holdings, Inc.

Registration Statement on Form S-1 (Registration No. 333-251828)

Ladies and Gentlemen:

In accordance with Rule 461 of Regulation C of the General Rules and Regulations under the Securities Act of 1933, as amended, we, as representatives of the several underwriters, hereby join in the request of Surgalign Holdings, Inc. (the “Company”) for acceleration of the effective date of the Registration Statement on Form S-1 (File No. 333-251828) so that it becomes effective as of 4:30 PM, Washington, D.C. time, on January 27, 2021, or as soon as practicable thereafter, or at such other time thereafter as the Company or its outside counsel, Sidley Austin LLP, may request by telephone to the staff of the U.S. Securities and Exchange Commission.

Pursuant to Rule 460 under the Act, we, as representatives of the several underwriters, wish to advise you that there will be distributed to each underwriter or dealer, who is reasonably anticipated to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned, as representatives of the several underwriters, advise that they have complied and will continue to comply, and each other participating underwriter has advised the undersigned that it has complied and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

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