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SEC Company Response from Xtant Medical Holdings, Inc. (XTNT) (CIK 0001453593) (XTNT) — Apr 25, 2018

Xtant Medical Holdings, Inc. (XTNT) (CIK 0001453593)
Date: April 25, 2018 · CIK: 0001453593 · Accession: 0001144204-18-022350

AI Filing Summary & Sentiment

File numbers found in text: 333-222918

Date
April 25, 2018
Author
Chief
Form
CORRESP
Company
Xtant Medical Holdings, Inc. (XTNT) (CIK 0001453593)

Letter

Re: Xtant Medical Holdings, Inc. (the “Company”)

April 25, 2018

BY ELECTRONIC FILING

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street N.E.

Washington D.C. 20549

Attention: Jeffrey Gabor and Irene Paik

Amendment No. 1 to Registration Statement on Form S-1

File No. 333-222918

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 referred to above be accelerated so that it will be declared effective at 4:30 PM on April 27, 2018, or as soon thereafter as is practicable.

The Company hereby acknowledges that:

· should 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 this action 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,
XTANT
MEDICAL HOLDINGS, INC.

Show Raw Text
CORRESP
1
filename1.htm

April 25, 2018

BY ELECTRONIC FILING

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street N.E.

Washington D.C. 20549

Attention: Jeffrey Gabor and Irene Paik

 Re: Xtant Medical Holdings, Inc. (the “Company”)

Amendment No. 1 to Registration Statement on Form S-1

File No. 333-222918

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 referred
to above be accelerated so that it will be declared effective at 4:30 PM on April 27, 2018, or as soon thereafter as is practicable.

The Company hereby acknowledges that:

 · should 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 this action 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,

XTANT
MEDICAL HOLDINGS, INC.

/s/
Carl O’Connell

Carl
O’Connell

Chief
Executive Officer

 cc: Travis Leach, Ballard Spahr LLP