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CORRESP Filing

SHOULDER INNOVATIONS, INC.
Date: July 28, 2025 · CIK: 0001699350 · Accession: 0001628280-25-036179

Offering / Registration Process

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File numbers found in text: 333-288549

Date
July 28, 2025
Author
Robert Ball
Form
CORRESP
Company
SHOULDER INNOVATIONS, INC.

Letter

Document Shoulder Innovations, Inc. 1535 Steele Avenue SW, Suite B Grand Rapids, Michigan 49507 July 28, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549-6010 Attention: Al Pavot Li Xiao Juan Grana Jane Park Re: Shoulder Innovations, Inc. Registration Statement on Form S-1, as amended (File No. 333-288549) Request for Acceleration of Effective Date To the addressees set forth above: In accordance with Rule 461 under the Securities Act of 1933, as amended, Shoulder Innovations, Inc. (the “ Company ”) hereby requests acceleration of the effective date of the above-referenced Registration Statement on Form S-1 (File No. 333-288549) (as amended, the “ Registration Statement ”). The Company respectfully requests that the Registration Statement become effective as of 4:00 p.m., Eastern Time, on July 30, 2025, or as soon as practicable thereafter, or at such other time as the Company or its legal counsel may request by telephone to the staff of the Division of Corporation Finance of the Securities and Exchange Commission. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Latham & Watkins LLP, by calling Ross McAloon at (714) 755-8051. Thank you for your assistance in this matter. [ Signature page follows ] Sincerely, Shoulder Innovations, Inc. By: /s/ Robert Ball Name: Robert Ball Title: Chief Executive Officer and Executive Chairman cc: Jeffrey Points, Chief Financial Officer, Shoulder Innovations, Inc. B. Shayne Kennedy, Latham & Watkins LLP J. Ross McAloon, Latham & Watkins LLP Denny Won, Cooley LLP Charles S. Kim, Cooley LLP Kristin VanderPas, Cooley LLP Dave Peinsipp, Cooley LLP

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CORRESP
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 Document Shoulder Innovations, Inc. 1535 Steele Avenue SW, Suite B Grand Rapids, Michigan 49507 July 28, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549-6010 Attention: Al Pavot Li Xiao Juan Grana Jane Park Re: Shoulder Innovations, Inc. Registration Statement on Form S-1, as amended (File No. 333-288549) Request for Acceleration of Effective Date To the addressees set forth above: In accordance with Rule 461 under the Securities Act of 1933, as amended, Shoulder Innovations, Inc. (the “ Company ”) hereby requests acceleration of the effective date of the above-referenced Registration Statement on Form S-1 (File No. 333-288549) (as amended, the “ Registration Statement ”). The Company respectfully requests that the Registration Statement become effective as of 4:00 p.m., Eastern Time, on July 30, 2025, or as soon as practicable thereafter, or at such other time as the Company or its legal counsel may request by telephone to the staff of the Division of Corporation Finance of the Securities and Exchange Commission. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Latham & Watkins LLP, by calling Ross McAloon at (714) 755-8051. Thank you for your assistance in this matter. [ Signature page follows ] Sincerely, Shoulder Innovations, Inc. By: /s/ Robert Ball Name: Robert Ball Title: Chief Executive Officer and Executive Chairman cc: Jeffrey Points, Chief Financial Officer, Shoulder Innovations, Inc. B. Shayne Kennedy, Latham & Watkins LLP J. Ross McAloon, Latham & Watkins LLP Denny Won, Cooley LLP Charles S. Kim, Cooley LLP Kristin VanderPas, Cooley LLP Dave Peinsipp, Cooley LLP