September 9, 2024

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 September 3, 2024
           File No. 333-281910
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 Alan Campbell at 202-551-4224 with any questions.



                                                           Sincerely,

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