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CORRESP
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filename1.htm

Amedica
Corporation

1885
West 2100 South

Salt
Lake City, Utah 84119

June
30, 2016

VIA
EDGAR

United
States Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
D.C. 20549

Attention:     Caleb
French

Re:
Amedica Corporation (the “Company”)

Registration
Statement on Form S-1

File
No. 333-211520

Ladies
and Gentlemen:

In
accordance with Rule 461 under the Securities Act of 1933, as amended, the undersigned respectfully requests that the effective
date for the Registration Statement on Form S-1 (File No. 333-211520), as amended (the “Registration Statement”),
be accelerated so that it will be declared effective at 5:00 p.m., Washington, D.C. time on July 1, 2016, or as soon thereafter
as is practicable. Once the Registration Statement has been declared effective, please confirm orally that event with our counsel,
Dorsey & Whitney LLP, by calling David Marx at (801) 933-7363.

The
Company hereby acknowledges that:

    ●
    should
    the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority,
    declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

    ●
    the
    action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not
    relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

    ●
    the
    Company may not assert comments of the Commission or the staff and the declaration of effectiveness as a defense in any proceeding
    initiated by the Commission or any person under the federal securities laws of the United States.

    Very
    truly yours,

    Amedica
    Corporation

    By:
    /s/
    Ty Lombardi

    Name:
    Ty
    Lombardi

    Title:
    Chief
    Financial Officer