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Correspondence 0001193125-23-079147 from GLOBUS MEDICAL INC (GMED) (CIK 0001237831) (GMED)

GLOBUS MEDICAL INC (GMED) (CIK 0001237831)
Date: March 24, 2023 · CIK: 0001237831 · Accession: 0001193125-23-079147

AI Filing Summary & Sentiment

File numbers found in text: 333-270482

Date
March 24, 2023
Author
President and Chief
Form
CORRESP
Company
GLOBUS MEDICAL INC (GMED) (CIK 0001237831)

Letter

VIA EDGAR Office of Industrial Applications and Services Division of Corporation Finance Washington, D.C. Attention: Ms. Jane Park Re: Acceleration Request of Globus Medical, Inc. Registration Statement of Form S-4, as amended (File No. 333-270482)

Dear Ms. Park:

In accordance with Rule 461 under the Securities Act of 1933, as amended (the “Act”), Globus Medical, Inc. (the “Company”) hereby requests that the effective date of the above-referenced registration statement (the “Registration Statement”) be accelerated to Tuesday, March 28, 2023, at 4:15 p.m. Eastern Time, or as soon thereafter as practicable. In making this acceleration request, the Company acknowledges that it is aware of its responsibilities under the Act.

Once the Registration Statement is effective, please orally confirm the event with our counsel, Goodwin Procter LLP by calling Laura Umbrecht at (445) 207-7815. We also respectfully request that a copy of the written order from the Securities and Exchange Commission verifying the effective time and date of the Registration Statement be sent to our counsel, Goodwin Procter LLP, Attention: Laura Umbrecht, by email at LUmbrecht@goodwinlaw.com.

[Signature Page Follows]

Very truly yours,
GLOBUS MEDICAL, INC.

Show Raw Text
CORRESP
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filename1.htm

CORRESP

 March 24, 2023

VIA EDGAR

 Office of Industrial Applications and
Services

 Division of Corporation Finance

 U.S. Securities
and Exchange Commission

 100 F Street, N.E.

 Washington, D.C.
20549

 Attention: Ms. Jane Park

Re:
 Acceleration Request of Globus Medical, Inc.

 Registration Statement of Form S-4, as amended (File No. 333-270482)

 Dear Ms. Park:

In accordance with Rule 461 under the Securities Act of 1933, as amended (the “Act”), Globus Medical, Inc. (the “Company”) hereby requests
that the effective date of the above-referenced registration statement (the “Registration Statement”) be accelerated to Tuesday, March 28, 2023, at 4:15 p.m. Eastern Time, or as soon thereafter as practicable. In making this
acceleration request, the Company acknowledges that it is aware of its responsibilities under the Act.

 Once the Registration Statement is effective,
please orally confirm the event with our counsel, Goodwin Procter LLP by calling Laura Umbrecht at (445) 207-7815. We also respectfully request that a copy of the written order from the Securities and Exchange
Commission verifying the effective time and date of the Registration Statement be sent to our counsel, Goodwin Procter LLP, Attention: Laura Umbrecht, by email at LUmbrecht@goodwinlaw.com.

[Signature Page Follows]

Very truly yours,

GLOBUS MEDICAL, INC.

/s/ Daniel T. Scavilla

 Daniel T. Scavilla

 President and Chief
Executive Officer

cc:
 Kelly G. Hueller, General Counsel, Globus Medical, Inc.

Rachael M. Bushey, Goodwin Procter LLP

Jennifer L. Porter, Goodwin Procter LLP

Laura K. Umbrecht, Goodwin Procter LLP