SecProbe.io

Mail Stop 3030

July 7 , 2017

Via E -Mail
Barry F. Cohen
Chief Executive Officer
AVRA Medical Robotics, Inc.
3259 Progress Drive Suite 126
Orlando, FL 32826

Re: AVRA Medical Robotics, Inc.
Amendment No. 2  to Registration Statement on Form S-1
Filed June 20 , 2017
  File No. 333-216054

Dear Mr. Cohen :

We have reviewed your amended registration statement and have the following
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 d o 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.   Unless we note
otherwise, our references to prior comments are to comments in our March 13, 2017 letter.

Results of Operations, page 36

Three months ended March 31, 2017 as compared to three months ended March 31, 2016, page
36

1. Please revise to discuss the underlying reason for the increase or decrease between
periods and not just state the amount of the change.   Refer to Item 303(a) of Regulation
S-K and Instruction 4 thereto.

Barry F. Cohen
AVRA Medical Robotics, Inc.
July 7 , 2017
Page 2

 Financial Statements

Note 1.   Organization and Basis of Accounting, page F -7

2. Refer to comment 3.   Your agreement with UCF states that you provide d UCF with
proprietary information described as a prototype surgical robotic device. Please address
the following:

 Tell us where you recorded the costs you incurred to develop the referenced
prototype.
 Provide us with a chronology of the development of th e AVRA technology (the
surgical robotic technology you use in your products) and the entities through which
you developed it.
 Since the underlying technology received FDA approval for skin resurfacing (page
31), tell us who developed the underlying technol ogy and how you reflected these
costs in your financial statements

Note 12. Subsequent Events, page F -17

3. You disclose that effective May 1, 2017, the research agreement with the University of
Central Florida was extended to June 30, 2019.   However, on pa ge F-13, you disclose
that under your agreement the university will accomplish the objectives as stated in the
statement of work over a period extending to June 30, 2017.   Please revise your
disclosure s to briefly indicate what implications the extension h as on the accomplishment
of the objectives under the agreement and the development of a surgical robotic device.

You may contact Julie Sherman at (202) 551 -3640 or Kate Tillan, Assistant Chief
Accountant, at (202) 551 -3604 if you have questions regarding comments on the financial
statements and related matters.  Please contact me at (202)  551-3528 with any other questions.

Sincerely,

 /s/ Amanda Ravitz

Amanda Ravitz
Assistant Director
Office of Electronics and Machinery

cc: Dale S. Bergman, Esq.
Gutierrez Bergman Boulris, PLLC