SEC Company Response from Xtant Medical Holdings, (XTNT) — Feb 8, 2011

Xtant Medical Holdings, Inc.
Date: Feb. 8, 2011 · CIK: 0001453593 · Accession: 0001144204-11-006494

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File numbers found in text: 333-169620

Date

Feb. 8, 2011

Author

Form

CORRESP

Company

Xtant Medical Holdings, Inc.

Letter

Via Edgar Securities and Exchange Commission Bacterin International Holdings, Inc. Registration Statement on Form S-1 File No. 333-169620

Re:

Dear Mr. Riedler:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Bacterin International Holdings, Inc. (the “Company”) requests acceleration of the effective date of the above-referenced Registration Statement so that the same shall become effective as of 5:00 p.m. Eastern Time on February 10, 2011, or as soon thereafter as possible.

The Company hereby acknowledges that

Should the Commission or the Staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

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

The Company may not assert Staff comments 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,
By:

Show Raw Text

CORRESP
1
filename1.htm

    Unassociated Document

      Via
Edgar

      February
8, 2011

      Securities
and Exchange Commission

      100 F
Street, N.E.

      Washington
D.C. 20549

      Attn:  Jeffrey
Riedler, Assistant Director

                Re:

                Bacterin
      International Holdings, Inc.

      Registration Statement on Form
S-1

      File No. 333-169620

      Dear Mr.
Riedler:

      Pursuant
to Rule 461 under the Securities Act of 1933, as amended, Bacterin International
Holdings, Inc. (the “Company”) requests acceleration of the effective date of
the above-referenced Registration Statement so that the same shall become
effective as of 5:00 p.m. Eastern Time on February 10, 2011, or as soon
thereafter as possible.

      The
Company hereby acknowledges that

                ·

                Should
      the Commission or the Staff, acting pursuant to delegated authority,
      declare the Registration Statement effective, it does not foreclose the
      Commission from taking any action with respect to the Registration
      Statement;

                ·

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

                ·

                The
      Company may not assert Staff comments 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,

                    By:

                  /s/ John
      Gandolfo

                  Name:
                  John
      Gandolfo

                  Title:
                  Chief
      Financial Officer

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