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CORRESP
1
filename1.htm

Amedica
Corporation

1885
West 2100 South

Salt
Lake City, Utah 84119

May
8, 2018

VIA
EDGAR

United
States Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
D.C. 20549

Attention:
Tom Jones

Re:
Amedica Corporation – Registration Statement on Form S-1 (File No. 333-223032)

Ladies
and Gentlemen:

In
accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of
the Registration Statement on Form S-1 (File No. 333-223032), as amended (the “Registration Statement”) of Amedica
Corporation. We respectfully request that the Registration Statement become effective as of 9:00 a.m., Eastern Time, on May 10,
2018, 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.

    Very
    truly yours,

    Amedica
    Corporation

    By:
    /s/
    B. Sonny Bal

    Name:
    B.
    Sonny Bal, M.D.

    Title:
    Chief
    Executive Officer and President

May
8, 2018

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
DC 20549

    Attn:
    Tom
    Jones

    Re:
    Amedica
    Corporation.

Registration
Statement on Form S-1, as amended (File No. 333-223032)

Ladies
and Gentlemen:

As
the dealer-manager of the proposed unit offering of Amedica Corporation (the “Company”), we hereby join
the Company’s request for acceleration of the above-referenced Registration Statement, requesting effectiveness for 9:00
a.m., Eastern Time, on May 10, 2018, or as soon thereafter as is practicable.

Pursuant
to Rule 460 of the General Rules and Regulations under the Securities Act of 1933, we wish to advise you that we have effected
the following distribution of the Company’s Preliminary Prospectus dated May 4, 2018, through the date hereof:

Preliminary
Prospectus dated May 4, 2018:

    Copies
    to underwriters:
    1

    Copies
    to prospective dealers:
    12

    Copies
    to prospective institutional investors:
    78

    Copies
    to prospective retail investors:
    376

The
undersigned advise that they have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934,
as amended.

    Very truly yours,

    Maxim Group LLC

    By:
    /s/
    Clifford A. Teller

    Name:
    Clifford
    A. Teller

    Title:
    Head
    of Investment Banking, Executive

    Managing
    Director