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AVRA MEDICAL ROBOTICS, INC.

3259 Progress
Drive Suite 126

Orlando,
FL 32826

June 20, 2017

Via EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Mail Stop 3030

100 “F” Street, N.E.

Washington, D.C. 20549-3629

    Attention:
    Ms. Laurie Abbott

    Ms. Amanda Ravitz

    Ms. Julie Sherman

    Ms. Kate Tillan

Re:  AVRA Medical
Robotics, Inc.

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

    Filed May 11, 2017

    File No. 333-216054

Ladies and Gentlemen:

In response to the Staff’s letter
of June 2, 2017, AVRA Medical Robotics, Inc. (the “Company”) hereby files Amendment No. 1 to the Registration
Statement on Form S-1.

The following sets forth the Company’s
response to the comments set forth in the Staff’s letter. For your convenience, the response to each comment follows the
comment itself.

Selling Shareholders,
page 20

Comment:

 1. We note your response to our prior
comment
number 11. As an affiliate
of yours, it appears that Mr. Cohen may
have facilitated
a distribution
of shares by you without registration
to the referenced “third
parties” as
statutory underwriter.
Provide your analysis
of how sales to the
third parties was not such
a distribution,
or provide additional disclosure explaining
that these sales may
not have been conducted in compliance with
Section 5 of the Securities Act of 1933

Response:

We believe that the transfers and sales
of shares by Mr. Cohen did not constitute a distribution, but rather a limited number of transfers and sales pursuant to exemptions
from the registration requirements of the Securities Act of 1933, as amended (the “Securities Act”). The transfers
and sales, all of which occurred in 2016 and early 2017 prior to filing of the registration statement consisted of:

 · The transfer of 1,527,000 shares without consideration for estate planning purposes to 13 family
members, which transactions were exempt from the registration requirements of the Securities Act as they did not constitute a “sale”
of a security pursuant to Section 2(a)(3) thereof.

Securities and Exchange Commission

Division of Corporation Finance

June 20, 2017

Page 2

 · The sale of 1,350,000 shares to five non-affiliated parties in privately negotiated transactions
pursuant to the so called “Section 4(a)1-1/2” exemption from the registration requirements of the Securities
Act, each purchaser having entered into a written agreement with the seller and having provided customary investment representations.

Financial Statements

Report of Independent Registered
Public Accounting
Firm, page F-2

Comment:

 2. Please refer to comment
27. The audit report refers to the
audit of the year ended December 31, 2015
whereas your financial
statements
are presented for the period
from inception (February
4, 2015) to December
31, 2015. Please request your auditors
to revise their audit report to refer to this
period and not the
year ended December
31, 2015.

Response:

The auditors report has been revised
to correct the periods covered thereby.

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

Comment:

 3. Please refer to comment
28. We do not see where
your revised disclosure responds to our comment.
Please tell us about your
relationship with AVRA
Surgical and tell us whether the
AVRA technology being used by AVRA
Medical Robotics was initially
developed by AVRA
Surgical.
Also include a chronology of the development
of the AVRA technology (the
surgical robotic
technology being used in your products) and the entities through which it was developed.

Response:

We hereby advise the Staff that other
than the involvement of Messrs. Cohen and Schauer as officers and/or directors of both companies, there is no legal, corporate
or financial relationship whatsoever between the Company and AVRA Surgical, Inc. Moreover, the Company is not using any of the
technology that AVRA Surgical, Inc. had in development. All the technology being used by the Company in developing its products
has been developed in conjunction with the University of Central Florida, pursuant to the Research Agreement entered into on May
1, 2016, as disclosed in the registration statement.

Note 3. Research
Collaboration Agreement,
page F-10

Comment:

 4. As requested in comment
29, please disclose how
you account for research
and development expenses.
Refer to ASC 730-10-25-1.

Response:

The disclosure regarding how the Company
accounts for research and development expenses has been added as requested to the Staff.

Securities and Exchange Commission

Division of Corporation Finance

June 20, 2017

Page 3

If you have any further questions
or comments, kindly contact the undersigned at (407) 956-2250 or our counsel, Dale S. Bergman, Esq. of Gutiérrez Bergman
Boulris, PLLC at (786) 888-1744.

Very
truly yours,

AVRA
MEDICAL ROBOTICS, INC.

By:  /s/ Barry F. Cohen

Barry
F. Cohen

Chief
Executive Officer