SEC Comment Letter for Xtant Medical Holdings, Inc. (XTNT) (CIK 0001453593) (XTNT) — May 23, 2018
Xtant Medical Holdings, Inc. (XTNT) (CIK 0001453593)
Date: May 23, 2018 · CIK: 0001453593 · Accession: 0000000000-18-015998
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May 23, 2018
Carl O’Connell
Chief Executive Officer
Xtant Medical Holdings, Inc.
664 Cruiser Lane
Belgrade, MT 59714
Re:Xtant Medical Holdings, Inc.
Registration Statement on Form S-1
Filed May 15, 2018
Amendment No. 1 to Registration Statement on Form S-1
Filed May 16, 2018
File No. 333-224940
Dear Mr. O’Connell:
We have limited our review of your registration statement to those issues we have
addressed in our comments. In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Amendment No. 1 to Registration Statement on Form S-1
Incorporation of Certain Documents by Reference, page 24
1.Please incorporate by reference your Definitive Proxy Statement on Schedule 14A filed
on January 22, 2018, the amendment to your Quarterly Report on Form 10-Q for the
quarterly period ended March 31, 2017 filed on March 30, 2018 and the amendment
to your Quarterly Report on Form 10-Q for the quarterly period ended June 30, 2017 filed
on March 30, 2018.
FirstName LastNameCarl O’Connell
Comapany NameXtant Medical Holdings, Inc.
May 23, 2018 Page 2
FirstName LastName
Carl O’Connell
Xtant Medical Holdings, Inc.
May 23, 2018
Page 2
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.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Ada D. Sarmento at 202-551-3798 or Erin Jaskot at 202-551-3442 with
any questions.
Division of Corporation Finance
Office of Healthcare & Insurance
cc: Amy E. Culbert, Esq.