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SEC Company Response from Xtant Medical Holdings, Inc. (XTNT) (CIK 0001453593) (XTNT) — Jun 3, 2016

Xtant Medical Holdings, Inc. (XTNT) (CIK 0001453593)
Date: June 3, 2016 · CIK: 0001453593 · Accession: 0001144204-16-106788

AI Filing Summary & Sentiment

Date
June 3, 2016
Author
Not clearly detected
Form
CORRESP
Company
Xtant Medical Holdings, Inc. (XTNT) (CIK 0001453593)

Letter

Re: Xtant Medical Holdings, Inc. Registration Statement on Form S-1 (File No. 333- 208677)

June 3, 2016

VIA EDGAR

Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington, D.C. 20549

Ladies and Gentlemen:

Xtant Medical Holdings, Inc. (the “Company”) hereby requests, pursuant to Rule 461 under the Securities Act of 1933, as amended, that the effectiveness of the above-referenced Registration Statement be accelerated to 5:00 p.m., Washington, D.C. time, on June 7, 2016, or as soon thereafter as practicable.

The Company 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 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.

[Remainder of page intentionally left blank]

Very truly yours,
Xtant Medical Holdings, Inc.

Show Raw Text
CORRESP
1
filename1.htm

June 3, 2016

VIA EDGAR

Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington, D.C. 20549

 Re: Xtant Medical Holdings, Inc. Registration Statement
on Form S-1 (File No. 333- 208677)

Ladies and Gentlemen:

Xtant Medical Holdings, Inc. (the “Company”)
hereby requests, pursuant to Rule 461 under the Securities Act of 1933, as amended, that the effectiveness of the above-referenced
Registration Statement be accelerated to 5:00 p.m., Washington, D.C. time, on June 7, 2016, or as soon thereafter as practicable.

The Company 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 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.

[Remainder of page intentionally left
blank]

    Very truly yours,

    Xtant Medical Holdings, Inc.

    By:
    /s/ John P. Gandolfo

    Name: John P. Gandolfo

    Title: Chief Financial Officer

 cc: James R. Tanenbaum, Esq.

Morrison & Foerster LLP