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April 27, 2020
Liron Carmel
Chief Executive Officer
Medigus Ltd.
Omer Industrial Park, No. 7A, P.O. Box 3030
Omer 8496500, Israel
Re:Medigus Ltd.
Registration Statement on Form F-3
Filed April 21, 2020
File No. 333-237774
Dear Mr. Carmel:
            We have limited our review of your registration statement to the issue we have addressed
in our comment.  In our comment, 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 comment applies 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 this comment, we may have additional comments.
Registration Statement on Form F-3 filed April 21, 2020
General
1.You do not appear to be eligible to omit the names of the selling securityholders prior to
effectiveness of the registration statement. Please revise or advise. Refer to General
Instruction II.H to Form F-3.
            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.

 FirstName LastNameLiron Carmel
 Comapany NameMedigus Ltd.
 April 27, 2020 Page 2
 FirstName LastName
Liron Carmel
Medigus Ltd.
April 27, 2020
Page 2
            Please contact Irene Paik at 202-551-6553 or Joseph McCann at 202-551-6262 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Shachar Hadar, Adv.