SecProbe.io

CORRESP
 1
 filename1.htm

 SINTX
Technologies, Inc.

 1885
West 2100 South

 Salt
Lake City, UT 84119

 December
9, 2025

 VIA
EDGAR

 United
States Securities and Exchange Commission

 Division
of Corporation Finance

 100
F. Street, N.E.

 Washington,
D.C. 20549

 Attention:
Margret Sewicky and Nick O'Leary

 Re:
 SINTX Technologies, Inc. – Registration Statement on Form S-3 (File No. 333-290628)

 Ladies
and Gentlemen:

 In
accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration
Statement on Form S-3 (File No. 333-290628) (the "Registration Statement") of SINTX Technologies, Inc. We respectfully request
that the Registration Statement become effective as of 4:30 p.m., Eastern Time, on December 11, 2025, or as soon thereafter as is practicable.
Once the Registration Statement has been declared effective, please confirm orally that event with our counsel, Dorsey & Whitney
LLP, by calling Dan Lyman at (801) 933-4028.

 Very
 truly yours,

 SINTX
 Technologies, Inc.

 By:
 /s/
 Eric Olson

 Name:
 Eric
Olson

 Title:
 Chief
Executive Officer

CORRESP
 1
 filename1.htm

 SINTX
Technologies, Inc.

 1885
West 2100 South

 Salt
Lake City, UT 84119

 March
26, 2025

 VIA
EDGAR

 United
States Securities and Exchange Commission

 Division
of Corporation Finance

 100
F. Street, N.E.

 Washington,
D.C. 20549

 Attention:
Juan Grana

 Re:
 SINTX Technologies, Inc. – Registration Statement on Form S-3 (File No. 333-285932)

 Ladies
and Gentlemen:

 In
accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration
Statement on Form S-3 (File No. 333-285932) (the "Registration Statement") of SINTX Technologies, Inc. We respectfully request
that the Registration Statement become effective as of 4:30 p.m., Eastern Time, on March 27, 2025, or as soon thereafter as is practicable.
Once the Registration Statement has been declared effective, please confirm orally that event with our counsel, Dorsey & Whitney
LLP, by calling Dan Lyman at (801) 933-4028.

 Very truly
 yours,

 SINTX Technologies,
 Inc.

 By:
 /s/
 Eric Olson

 Name:
 Eric Olson

 Title:
 Chief Executive Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 25, 2025

Eric Olson
Chief Executive Officer
SINTX Technologies, Inc.
1885 West 2100 South
Salt Lake City, UT 84119

 Re: SINTX Technologies, Inc.
 Registration Statement on Form S-3
 Filed March 19, 2025
 File No. 333-285932
Dear Eric Olson:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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.

 Please contact Juan Grana at 202-551-6034 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
cc: David Marx, Esq.
</TEXT>
</DOCUMENT>

CORRESP
1
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January
29, 2024

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549-1004

    Re:
    Sintx
    Technologies, Inc.

    Registration
    Statement on Form S-1, as amended

    File
    No. 333-275137

Ladies
and Gentlemen:

As
the placement agent of the proposed offering of Sintx Technologies, Inc. (the “Company”),
we hereby join the Company’s request for acceleration of the above-referenced Registration Statement, requesting effectiveness
for 9:00 a.m., Eastern Time, on Wednesday, January 31, 2024, or as soon thereafter as is practicable.

Pursuant
to Rule 460 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as
amended, we wish to advise you that, through January 29, 2024, we distributed to each dealer, who is reasonably anticipated to be invited
to participate in the distribution of the security, as many copies, as well as “E-red” copies of the Preliminary Prospectus
dated January 24, 2024, as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The
undersigned advise that they have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as
amended.

    Very
    truly yours,

    Maxim
    Group LLC

    By:

    /s/
    Clifford A. Teller

    Name:
    Clifford
    A. Teller

    Title:
    Co-President

CORRESP
1
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SINTX
Technologies, Inc.

1885
West 2100 South

Salt
Lake City, Utah 84119

January
29, 2024

VIA
EDGAR

United
States Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
D.C. 20549

Attention:
Ben Ritchie

Re:
SINTX Technologies, Inc. – Registration Statement on Form S-1 (File No. 333-275137)

Ladies
and Gentlemen:

In
accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration
Statement on Form S-1 (File No. 333-275137), as amended (the “Registration Statement”) of SINTX Technologies, Inc. We respectfully
request that the Registration Statement become effective as of 9:00 a.m., Eastern Time, on January 31, 2024, or as soon thereafter as
is reasonably practicable. Once the Registration Statement has been declared effective, please confirm orally that event with our counsel,
Dorsey & Whitney LLP, by calling David Marx at (801) 933-7363.

    Very truly
    yours,

    SINTX Technologies,
    Inc.

    By:
    /s/
    B. Sonny Bal

    Name:
    B.
    Sonny Bal, M.D.

    Title:
    Chief
    Executive Officer

CORRESP
1
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SINTX
Technologies, Inc.

1885
West 2100 South

Salt
Lake City, Utah 84119

November
24, 2023

VIA
EDGAR

United
States Securities and Exchange Commission

Division
of Corporate Finance

100
F Street, N.E.

Washington,
D.C. 20549

    Re:
    SINTX
Technologies, Inc.—Registration Statement on Form S-3 (File No. 333-274951)

Ladies
and Gentlemen:

In
accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration
Statement on Form S-3 (File No. 333-274951) (as amended, the “Registration Statement”) of SINTX Technologies, Inc. (the “Company”).
We respectfully request that the Registration Statement be declared effective as of 5:00 p.m., Eastern Time, on November 27, 2023,
or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with
our counsel, Dorsey & Whitney LLP, by calling David Marx at (801) 933-7363.

    Very
    truly yours,

    SINTX
    Technologies, Inc.

    By:
    /s/
    B. Sonny Bal

    Name:
    B.
    Sonny Bal, M.D.

    Title:
    Chief
    Executive Officer

CORRESP
1
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SINTX
Technologies, Inc.

1885
West 2100 South

Salt
Lake City, Utah 84119

    November
    9, 2023
    Via
    Edgar

United
States Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549

Attention:
Nicholas O’Leary

Re:
SiNtx Technologies, Inc. - Registration Statement on Form S-1 (File No. 333-275137)

Ladies
and Gentlemen:

Reference
is made to our letter, filed as correspondence via EDGAR on November 6, 2023, in which we requested the acceleration of the effective
date of the above-referenced Registration Statement for Wednesday, November 8, 2023, at 5:30 p.m. Eastern Time, in accordance with Rule
461 under the Securities Act of 1933, as amended. We are no longer requesting that such Registration Statement be declared effective
at this time, and we hereby formally withdraw our request for acceleration of the effective date.

    Very
    truly yours,

    SiNtx
    Technologies, Inc.

    By:
    /s/
    B. Sonny Bal

    Name:

    B.
    Sonny Bal

    Title:

    Chief
    Executive Officer

CORRESP
1
filename1.htm

November
9, 2023

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

100
F Street, NE

Washington,
DC 20549

    Re:
    SINTX
    Technologies, Inc.

    Registration
    Statement on Form S-1, as amended

    File
    No. 333-275137

Ladies
and Gentlemen:

As
the underwriter of the proposed offering of SINTX Technologies, Inc.
(the “Company”), we hereby withdraw our prior letter to join the acceleration
request of the Company dated November 6, 2023 for the above-referenced Registration Statement.

    Very
    truly yours,

    Maxim
    Group LLC

    By:

    /s/
    Clifford A. Teller

    Name:
    Clifford
    A. Teller

    Title:
     Co-President

CORRESP
1
filename1.htm

SINTX
Technologies, Inc.

1885
West 2100 South

Salt
Lake City, Utah 84119

November
6, 2023

VIA
EDGAR

United
States Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
D.C. 20549

Attention:
Nicholas O’Leary

Re:
SiNtx Technologies, Inc. – Registration Statement on Form S-1 (File No. 333-275137)

Ladies
and Gentlemen:

In
accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration
Statement on Form S-1 (File No. 333-275137), as amended (the “Registration Statement”) of SINTX Technologies, Inc. We respectfully
request that the Registration Statement become effective as of 5:30 p.m., Eastern Time, on November 8, 2023, or as soon thereafter as
is reasonably practicable. Once the Registration Statement has been declared effective, please confirm orally that event with our counsel,
Dorsey & Whitney LLP, by calling David Marx at (801) 933-7363.

    Very
    truly yours,

    SINTX
    Technologies, Inc.

    By:
    /s/
    B. Sonny Bal

    Name:
    B.
    Sonny Bal, M.D.

    Title:
    Chief
    Executive Officer

CORRESP
1
filename1.htm

November
6, 2023

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549-1004

    Re:
    Sintx
    Technologies, Inc.

    Registration
    Statement on Form S-1, as amended

    File
    No. 333-275137

Ladies
and Gentlemen:

As
the placement agent of the proposed offering of Sintx Technologies, Inc. (the “Company”), we hereby join the Company’s
request for acceleration of the above-referenced Registration Statement, requesting effectiveness for 5:30 p.m., Eastern Time, on Wednesday,
November 8, 2023, or as soon thereafter as is practicable.

Pursuant
to Rule 460 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as
amended, we wish to advise you that, through November 6, 2023, we distributed to each dealer, who is reasonably anticipated to be invited
to participate in the distribution of the security, as many copies, as well as “E-red” copies of the Preliminary Prospectus
dated November 2, 2023, as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The
undersigned advise that they have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as
amended.

    Very
    truly yours,

    Maxim
    Group LLC

    By:

    /s/
    Clifford A. Teller

    Name:
    Clifford A. Teller

    Title:
    Co-President

United States securities and exchange commission logo
October 30, 2023
B. Sonny Bal, M.D.
Chief Executive Officer and President
Sintx Technologies, Inc.
1885 West 2100 South
Salt Lake City, UT 84119
Re:Sintx Technologies, Inc.
Registration Statement on Form S-1
Filed October 23, 2023
File No. 333-275137
Dear B. Sonny Bal, M.D.:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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.
            Please contact Nicholas O'Leary at 202-551-4451 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       David Marx, Esq.

United States securities and exchange commission logo
October 20, 2023
B. Sonny Bal, M.D.
President and Chief Executive Officer
Sintx Technologies, Inc.
1885 West 2100 South
Salt Lake City, Utah 84119
Re:Sintx Technologies, Inc.
Registration Statement on Form S-3
Filed October 12, 2023
File No. 333-274951
Dear B. Sonny Bal, M.D.:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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.
            Please contact Abby Adams at 202-551-6902 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Kevin J. Ontiveros, Esq.

CORRESP
1
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SINTX
Technologies, Inc.

1885
West 2100 South

Salt
Lake City, Utah 84119

February
7, 2023

VIA
EDGAR

United
States Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
D.C. 20549

Attention:
Margaret Schwartz

Re:
SiNtx Technologies, Inc. – Registration Statement on Form S-1 (File No. 333-269475)

Ladies
and Gentlemen:

In
accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration
Statement on Form S-1 (File No. 333-269475), as amended (the “Registration Statement”) of SINTX Technologies, Inc. We respectfully
request that the Registration Statement become effective as of 5:00 p.m., Eastern Time, on February 7, 2023, or as soon thereafter as
is reasonably practicable. Once the Registration Statement has been declared effective, please confirm orally that event with our counsel,
Dorsey & Whitney LLP, by calling David Marx at (801) 933-7363.

    Very
    truly yours,

    SINTX
    Technologies, Inc.

    By:
    /s/
    B. Sonny Bal

    Name:
    B.
    Sonny Bal, M.D.

    Title:
    Chief
    Executive Officer

United States securities and exchange commission logo
February 3, 2023
B. Sonny Ball
Chief Executive Officer and President
Sintx Technologies, Inc.
1885 West 2100 South
Salt Lake City, UT, 84119
Re:Sintx Technologies, Inc.
Registration Statement on Form S-1
Filed January 31, 2023
File No. 333-269475
Dear B. Sonny Ball:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Jessica Ansart at 202-551-4511 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       David Marx

CORRESP
1
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SINTX
Technologies, Inc.

1885
West 2100 South

Salt
Lake City, Utah 84119

September
21, 2022

VIA
EDGAR

United
States Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
D.C. 20549

Attention:
Margaret Schwartz

Re:
SiNtx Technologies, Inc. – Registration Statement on Form S-1 (File No. 333-266070)

Ladies
and Gentlemen:

In
accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration
Statement on Form S-1 (File No. 333-266070), as amended (the “Registration Statement”) of SINTX Technologies, Inc. We respectfully
request that the Registration Statement become effective as of 5:00 p.m., Eastern Time, on September 23, 2022, or as soon thereafter
as is practicable. Once the Registration Statement has been declared effective, please confirm orally that event with our counsel, Dorsey
& Whitney LLP, by calling David Marx at (801) 933-7363.

    Very
    truly yours,

    SINTX
    Technologies, Inc.

    By:
    /s/
    B. Sonny Bal

    Name:
    B.
    Sonny Bal, M.D.

    Title:
    Chief
    Executive Officer

United States securities and exchange commission logo
July 14, 2022
B. Sonny Bal, M.D.
Chief Executive Officer and President
Sintx Technologies, Inc.
1885 West 2100 South
Salt Lake City, UT, 84119
Re:Sintx Technologies, Inc.
Registration Statement on Form S-1
Filed July 8, 2022
File No. 333-266070
Dear Dr. Bal:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Margaret Schwartz at 202-551-7153 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       David Marx, Esq.

CORRESP
1
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SINTX
Technologies, Inc.

1885
West 2100 South

Salt
Lake City, Utah 84119

October
8, 2020

VIA
EDGAR

United
States Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
D.C. 20549

Attention:
Jeffrey Gabor

Re:
SINTX Technologies, Inc. – Registration Statement on Form S-3 (File No. 333-249267)

Ladies
and Gentlemen:

In
accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of
the Registration Statement on Form S-3 (File No. 333-249267), as amended (the “Registration Statement”) of SINTX Technologies,
Inc. We respectfully request that the Registration Statement become effective as of 5:00 p.m., Eastern Time, on October 13, 2020,
or as soon thereafter as is practicable. Once the Registration Statement has been declared effective, please confirm orally that
event with our counsel, by calling Kevin Ontiveros at (801) 450-7001.

    Very
    truly yours,

    SINTX
    Technologies, Inc.

    By:
    /s/
    B. Sonny Bal

    Name:
    B.
    Sonny Bal, M.D.

    Title:
    Chief
    Executive Officer and President

United States securities and exchange commission logo
October 6, 2020
B. Sonny Bal, M.D.
President and Chief Executive Officer
Sintx Technologies, Inc.
1885 West 2100 South
Salt Lake City, Utah 84119
Re:Sintx Technologies, Inc.
Registration Statement on Form S-3
Filed October 2, 2020
File No. 333-249267
Dear Dr. Bal:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Jeffrey Gabor at 202-551-2544 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Kevin J. Ontiveros, Esq.

CORRESP
1
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SINTX
Technologies, Inc.

1885
West 2100 South

Salt
Lake City, Utah 84119

January
15, 2020

VIA
EDGAR

United
States Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
D.C. 20549

Attention:
Joe McCann

Re:
SINTX Technologies, Inc. – Registration Statement on Form S-1 (File No. 333-234438)

Ladies
and Gentlemen:

In
accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of
the Registration Statement on Form S-1 (File No. 333-234438), as amended (the “Registration Statement”) of SINTX Technologies,
Inc. We respectfully request that the Registration Statement become effective as of 3:00 p.m., Eastern Time, on January
17, 2020, or as soon thereafter as is practicable. Once the Registration Statement has been declared effective, please confirm
orally that event with our counsel, Dorsey & Whitney LLP, by calling David Marx at (801) 933-7363.

    Very
    truly yours,

    SINTX
    Technologies, Inc.

    By:
    /s/
    B. Sonny Bal

    Name:
    B.
    Sonny Bal, M.D.

    Title:
    Chief
    Executive Officer and President

CORRESP
1
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B.
Sonny Bal, M.D.

President
and Chief Executive Officer

Sintx
Technologies, Inc.

1885
West 2100 South

Salt
Lake City, Utah 84119

December
9, 2019

VIA
EDGAR

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

Attn:
Mr. Joe McCann and Ms. Christine Westbrook

    Re:
    Sintx
    Technologies, Inc.

    Registration
    Statement on Form S-1

    Filed
    November 1, 2019

    File
    No. 333-234438

Dear
Mr. McCann and Ms. Westbrook:

We
are in receipt of the comments of the staff (the “Staff”) of the Securities and Exchange Commission
(the “Commission”) set forth in the Staff’s letter dated November 27, 2019 (the “SEC
Comment Letter”) regarding the above-referenced Registration Statement on Form S-1 (the “Registration
Statement”) filed by Sintx Technologies, Inc. (the “Company”). The numbered responses
set forth below contain each of the Staff’s comments in total set off in bold type and correspond to the numbered comments
contained in the SEC Comment Letter.

Concurrently
herewith, we are filing Amendment No. 1 to the registration statement on Form S-1 (the “Public Filing”).
The changes made in the Public Filing are in response to certain of the Staff’s comments as set forth in the SEC Comment
Letter.

Registration
Statement on Form S-1 filed November 1, 2019

Cover
Page:

    1.
    We
    note your disclosure that you may extend the rights offering in your sole discretion. Please revise your disclosure to state
    a termination date that is not indefinite. Refer to Item 501(b)(8)(iii) of Regulation S-K.

Response
to Comment No. 1:

The
Company respectfully advises the Staff that the Company has updated the disclosure on the cover page of the prospectus contained
in the Registration Statement, and throughout the Registration Statement as needed, to disclose that the Company may extend the
rights offering for additional periods in its sole discretion for any reason for up to an additional 45 days.

Securities
and Exchange Commission

December
9, 2019

Page
2

The
Rights Offering

No
Revocation or Change, page 25

    2.
    We
    note your disclosure that all exercises of subscription rights are irrevocable even if purchasers learn information about
    you that purchasers consider to be unfavorable. Please tell us the circumstances under which you will provide your shareholders
    with the right to revoke subscriptions in the event of material developments during the offering period.

Response
to Comment No. 2:

The
Company respectfully advises the Staff that the Company has updated the disclosure on page 25 of the prospectus contained in the
Registration Statement, and throughout the Registration Statement as needed, to include the following disclosure:

If
we should make any fundamental changes to the terms set forth in this prospectus, we will file a post-effective amendment to the
registration statement in which this prospectus is included, offer potential purchasers who have subscribed for rights the opportunity
to cancel such subscriptions and issue a refund of any money advanced by such stockholder or eligible warrant holder and recirculate
an updated prospectus after the post-effective amendment is declared effective with the SEC.

*   *   *

Securities
and Exchange Commission

December
9, 2019

Page
3

Please
contact the Company’s counsel, David F. Marx, of Dorsey & Whitney LLP, at (801) 933-7363 if you have any questions with
respect to this letter.

    Very
    truly yours,

    SINTX
    TECHNOLOGIES, INC.

    /s/
    B. SONNY BAL

    B. Sonny Bal, M.D.

                                                         President and Chief Executive Officer

cc: David
                                         F. Marx

November 27, 2019
B. Sonny Bal, M.D.
President and Chief Executive Officer
Sintx Technologies, Inc.
1885 West 2100 South
Salt Lake City, UT 84119
Re:Sintx Technologies, Inc.
Registration Statement on Form S-1
Filed November 1, 2019
File No. 333-234438
Dear Dr. Bal:
            We have limited our review of your registration statement to those issues we have
addressed in our 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 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 these comments, we may have additional comments.
Registration Statement on Form S-1 filed November 1, 2019
Cover page
1.We note your disclosure that you may extend the rights offering in your sole discretion.
Please revise your disclosure to state a termination date that is not indefinite. Refer to Item
501(b)(8)(iii) of Regulation S-K.
The Rights Offering
No Revocation or Change, page 25
2.We note your disclosure that all exercises of subscription rights are irrevocable even if
purchasers learn information about you that purchasers consider to be unfavorable. Please
tell us the circumstances under which you will provide your shareholders with the right to
revoke subscriptions in the event of material developments during the offering period.

 FirstName LastNameB. Sonny Bal, M.D.
 Comapany NameSintx Technologies, Inc.
 November 27, 2019 Page 2
 FirstName LastName
B. Sonny Bal, M.D.
Sintx Technologies, Inc.
November 27, 2019
Page 2

            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.
            Please contact Joe McCann at 202-551-6262 or Christine Westbrook at 202-551-5019
with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       David F. Marx, Esq.

CORRESP
1
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SINTX
Technologies, Inc.

1885
West 2100 South

Salt
Lake City, Utah 84119

April
3, 2019

VIA
EDGAR

United
States Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
D.C. 20549

Attention:
Tom Jones

Re:
SINTX Technologies, Inc. – Registration Statement on Form S-3 (File No. 333-230492)

Ladies
and Gentlemen:

In
accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of
the Registration Statement on Form S-3 (File No. 333-230492), as amended (the “Registration Statement”) of SINTX Technologies,
Inc. We respectfully request that the Registration Statement become effective as of 5:00 p.m., Eastern Time, on April 5, 2019,
or as soon thereafter as is practicable. Once the Registration Statement has been declared effective, please confirm orally that
event with our counsel, Dorsey & Whitney LLP, by calling Michael Newton at (801) 933-4037.

    Very
    truly yours,

    SINTX
    Technologies, Inc.

    By:
    /s/
    B. Sonny Bal

    Name:
    B.
    Sonny Bal, M.D.

    Title:
    Chief
    Executive Officer and President

April 2, 2019
B. Sonny Bal, MD
President and Chief Executive Officer
SINTX Technologies, Inc.
1885 West 2100 South
Salt Lake City, Utah 84119
Re:SINTX Technologies, Inc.
Registration Statement on Form S-3
Filed March 25, 2019
File No. 333-230492
Dear Dr. Bal:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Thomas Jones at 202-551-3602 with any questions.
Sincerely,
Division of Corporation Finance
Office of Electronics and Machinery
cc:       David Marx

CORRESP
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Amedica
Corporation

1885
West 2100 South

Salt
Lake City, Utah 84119

May
8, 2018

VIA
EDGAR

United
States Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
D.C. 20549

Attention:
Tom Jones

Re:
Amedica Corporation – Registration Statement on Form S-1 (File No. 333-223032)

Ladies
and Gentlemen:

In
accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of
the Registration Statement on Form S-1 (File No. 333-223032), as amended (the “Registration Statement”) of Amedica
Corporation. We respectfully request that the Registration Statement become effective as of 9:00 a.m., Eastern Time, on May 10,
2018, or as soon thereafter as is practicable. Once the Registration Statement has been declared effective, please confirm orally
that event with our counsel, Dorsey & Whitney LLP, by calling David Marx at (801) 933-7363.

    Very
    truly yours,

    Amedica
    Corporation

    By:
    /s/
    B. Sonny Bal

    Name:
    B.
    Sonny Bal, M.D.

    Title:
    Chief
    Executive Officer and President

May
8, 2018

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
DC 20549

    Attn:
    Tom
    Jones

    Re:
    Amedica
    Corporation.

Registration
Statement on Form S-1, as amended (File No. 333-223032)

Ladies
and Gentlemen:

As
the dealer-manager of the proposed unit offering of Amedica Corporation (the “Company”), we hereby join
the Company’s request for acceleration of the above-referenced Registration Statement, requesting effectiveness for 9:00
a.m., Eastern Time, on May 10, 2018, or as soon thereafter as is practicable.

Pursuant
to Rule 460 of the General Rules and Regulations under the Securities Act of 1933, we wish to advise you that we have effected
the following distribution of the Company’s Preliminary Prospectus dated May 4, 2018, through the date hereof:

Preliminary
Prospectus dated May 4, 2018:

    Copies
    to underwriters:
    1

    Copies
    to prospective dealers:
    12

    Copies
    to prospective institutional investors:
    78

    Copies
    to prospective retail investors:
    376

The
undersigned advise that they have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934,
as amended.

    Very truly yours,

    Maxim Group LLC

    By:
    /s/
    Clifford A. Teller

    Name:
    Clifford
    A. Teller

    Title:
    Head
    of Investment Banking, Executive

    Managing
    Director

CORRESP
1
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Amedica Corporation

1885 West 2100 South

Salt Lake City, Utah 84119

December 7, 2016

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

Attention:

Caleb French

Re: Amedica Corporation (the “Company”)

Registration Statement on Form S-3, as amended

File No. 333-214804

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 4:00 p.m., Washington, D.C. time on December 9, 2016, or as soon thereafter as is practicable.

Once the Registration Statement has been declared effective, or if you have any questions, please confirm orally that event with our counsel, Dorsey & Whitney LLP, by calling David Marx at (801) 933-7363.

Very truly yours,

Amedica Corporation

By:

            /s/ B. Sonny Bal

Name:

B. Sonny Bal

Title:

Chief Executive Officer, President and Chairman of the Board

Mail Stop 3030
December 7, 2016

Via E -mail
B. Sonny Bal, MD
President and Chief Executive Officer
Amedica Corporation
1885 West 2100 South
Salt Lake City, UT 84119

Re: Amedica  Corporation
  Registration Statement on Form S-3
Filed  November 25, 2016
  File No.  333-214804

Dear Dr. Bal :

This is to advise you that we have not  reviewed and will not review your registration
statement .

Please refer to Rules 460 and 461 regarding requests for acceleration.  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.

Please  contact Caleb French  at (202) 551 -6947  with any questions.

Sincerely,

 /s/ Caleb French for

 Amanda Ravitz
Assistant Director
Office of Electronics and Machinery

cc:  David F. Marx, Esq.
 Dorsey & Whitney LLP

CORRESP
1
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Amedica
Corporation

1885
West 2100 South

Salt
Lake City, Utah 84119

June
30, 2016

VIA
EDGAR

United
States Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
D.C. 20549

Attention:     Caleb
French

Re:
Amedica Corporation (the “Company”)

Registration
Statement on Form S-1

File
No. 333-211520

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 on Form S-1 (File No. 333-211520), as amended (the “Registration Statement”),
be accelerated so that it will be declared effective at 5:00 p.m., Washington, D.C. time on July 1, 2016, or as soon thereafter
as is practicable. Once the Registration Statement has been declared effective, please confirm orally that event with our counsel,
Dorsey & Whitney LLP, by calling David Marx at (801) 933-7363.

The
Company hereby acknowledges that:

    ●
    should
    the Securities and Exchange Commission (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 comments of the Commission or the staff and the declaration of effectiveness 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,

    Amedica
    Corporation

    By:
    /s/
    Ty Lombardi

    Name:
    Ty
    Lombardi

    Title:
    Chief
    Financial Officer

CORRESP
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June 30, 2016

VIA FACSIMILE AND EDGAR

U.S. Securities and Exchange Commission

Division of Corporate Finance

Washington, DC 20549

    Re:
    AMEDICA
    CORPORATION

    Registration
    Statement on Form S-1 (Registration No. 333-211520) -

    Concurrence
    in Acceleration Request

Ladies and Gentlemen:

Ladenburg Thalmann &
Co., Inc. (“Ladenburg”), as representative of the underwriters for the referenced offering, hereby concurs
in the request by Amedica Corporation that the effective date of the above-referenced registration statement be accelerated to
5:00 p.m. (Eastern Time), or as soon as practicable thereafter, on July 1, 2016, pursuant to Rule 461 under the Securities Act.
Ladenburg affirms that it is aware of its obligations under the Securities Act in connection with this offering.

    Very truly yours,

    LADENBURG THALMANN
    & CO. INC.

    By:
    /s/ Nicholas Stergis

    Name:
    Nicholas Stergis

    Title:
    Managing Director

Mail Stop 3030
June 6 , 2016

Via E -mail
B. Sonny Bal , MD
President and Chief Executive Officer
Amedica Corporation
1885 West 2100 South
Salt Lake City, UT, 84119

Re: Amedica  Corporation
  Registration Statement on Form S-1
Filed  May 23, 2016
  File No.  333-211520

Dear Dr. Bal :

This is to advise you that we have not  reviewed and will not review your registration
statement .

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are  in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

In the event you request acceleration of the effective date of the pending regist ration
statement , please provide  a written statement from the company acknowledging 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 t o 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 staff comments and the declaration of effect iveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

B. Sonny Bal
Amedica Corporation
June 6, 2016
Page 2

 Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceler ation of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the registered securities .

Please  contact Caleb French  at (202) 551 -6947  with any questions.

Sincerely,

 /s/ Caleb French for

 Amanda Ravitz
Assistant Director
Office of Electronics and Machinery

cc:  David F. Marx
 Dorsey & Whitney LLP

Mail Stop 3030

January 5, 2016

Via E -mail
Ty A. Lombardi
Vice President Finance
Amedica  Corporation
1885 West 2100 South
Salt Lake City, Utah   84119

Re: Amedica Corporation
Form 10 -K for Fiscal Year Ended  December 31, 2014
Filed March 24 , 2015
File No. 001 -33624

Dear Mr. Lombardi :

We have completed our review of your filing s.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing s and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United  States.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing s to be certain that the filing s include  the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

 /s/Brian Cascio

Brian Cascio
Accounting Branch Chief
Office Electronics and Machinery

CORRESP
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		CORRESP

December 17, 2015

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Mail Stop 3030

Washington, DC 20549

Attention: Brian Cascio, Accounting Branch Chief Office of Electronics and Machinery

Re:    Amedica Corporation

Form 10-K for Fiscal Year Ended December 31, 2014

Filed March 24, 2015

File No. 001-33624

Ladies and Gentlemen:

We are writing in response to the comment received from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) by letter dated December 3, 2015 relating to the Form 10-K for Fiscal Year Ended December 31, 2014 and our Quarterly Reports on Form 10-Q for the Quarters Ended March 31, 2015, June 30, 2015 and September 30, 2015, respectively  (the “Forms 10-Q”) previously filed with the Commission by Amedica Corporation (the “Company”). Amendments on Form 10K/A (the “Amended Form 10K”) for the aforementioned Form 10K and on Forms 10-Q/A for each of the aforementioned Forms10Q (the “Amended Forms 10-Q”), which reflect the Staff’s comment, were filed with the Commission on December 17, 2015. The Staff’s comment is presented in bold italics below.

Form 10-K for Fiscal Year Ended December 31, 2014

Exhibits 31.1 and 31.2

1.

 We see that the officer certifications do not include the language referring to internal control over financial reporting that should appear in the introductory sentence of paragraph 4 and paragraph 4(b). Please amend the filing to include the correct certifications. You may file an abbreviated amendment that includes a cover page, explanatory note, signature page and paragraphs 1, 2, 4 and 5 of the certification. Refer to Exchange Act Rule 13a-14(a) and Item 601(b)(31) of Regulation S-K. This comment also applies to your Forms 10-Q for the quarters ended March 31, 2015, June 30, 2015 and September 30, 2015.

In response to the Staff’s comment, the Amended Form 10-K and the Amended Forms 10Q for the quarters ended March 31, 2015, June 30, 2015 and September 30, 2015 contain updated Exhibits 31.1 and 31.2 with the corrected officer certifications.

Please be advised that the Company acknowledges to the Commission that:

Securities and Exchange Commission

December 17, 2015

Page 2

•

 the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

•

 staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

•

 the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

If the Staff has any questions please do not hesitate to contact me at (801) 839-3506.

Very truly yours,

/s/ Ty Lombardi

Ty Lombardi

Vice President Finance

Amedica Corporation

Cc: Andri Boerman

Gary Todd, Senior Accountant

Mail Stop 3030
December 3, 2015

Via E -mail
Ty A. Lombardi
Vice President Finance
Amedica  Corporation
1885 West 2100 South
Salt Lake City, Utah   84119

Re: Amedica Corporation
Form 10-K for Fiscal Year Ended  December 31, 2014
Filed March 24 , 2015
File No. 001 -33624

Dear Mr. Lombardi :

We have limited our review of your filing s to the financial statements and related
disclosures and have the following comment .  In some of our comment s, we may ask you to
provide us with information so we may better understand your disclosure.

Please respond to this comment  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comment applies  to your facts and circumstances , please tell us why in your response.

After reviewing your response to this comment , we may have additional comments.

Form 10 -K for Fiscal Year Ended December 31, 2014

Exhib its 31.1 and 31.2

1. We see that the officer certifications do not include the language referring to internal
control over financial reporting that should appear in the introductory sentence of
paragraph 4 and paragraph 4(b).  Please amend the filing to incl ude the correct
certifications.  You may file an abbreviated amendment that includes a cover page,
explanatory note, signature page and paragraphs 1, 2, 4 and 5 of the certification.  Refer
to Exchange Act Rule 13a -14(a) and Item 601(b)(31) of Regulation S -K.  This comment
also applies to your Forms 10 -Q for the quarters ended March 31, 2015, June 30, 2015
and September 30, 2015.

Ty A. Lombardi
Amedica  Corporation
December 3, 2015
Page 2

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the f iling includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

In responding to our comments, please provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact A ndri Boerman at (202) 551 -3645 or Gary Todd, Senior Accountant, at
(202) 5 51-3605 with any questions.  You may also reach  me at (202) 551 -3676.

Sincerely,

 /s/Gary Todd  for

Brian Cascio
Accounting Branch Chief
Office of Electronics and Machinery

CORRESP
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    amedica-corresp_110215.htm

Amedica Corporation

1885 West 2100 South

Salt Lake City, Utah 84119

November 2, 2015

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

Attention:  Geoffrey D. Kruczek

Re: Amedica Corporation (the “Company”)

Registration Statement on Form S-3

File No. 333-207289

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 4:00 p.m., Washington, D.C. time on November 4, 2015, or as soon thereafter as is practicable.  Once the Registration Statement has been declared effective, please confirm orally that event with our counsel, Dorsey & Whitney LLP, by calling Sam Gardiner at (801) 933-7362.

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 staff comments and the declaration of effectiveness 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,

Amedica Corporation

By:

 /s/ Ty Lombardi

Name: Ty Lombardi

Title:    Vice President Finance

CORRESP
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    amedica_corresp-10192015.htm

October 20, 2015

VIA EMAIL AND EDGAR

Ms. Amanda Ravitz

Assistant Director

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Re:        Amedica Corporation Form S-3, Filed on October 5, 2015

Dear Ms. Ravitz:

Set forth below is our response to your telephone call regarding the Registration Statement on Form S-3 (the “Registration Statement”) filed October 5, 2015 by Amedica Corporation (the “Company”) with the Securities and Exchange Commission (the “Commission”)

On September 8, 2015, the Company entered into a Securities Purchase Agreement (the “Purchase Agreement”) with three institutional investors (the “Investors”) pursuant to which the Company agreed to issue and sell, in a registered public offering by the Company directly to the Investors (the “Public Offering”), an aggregate of 13,123,360 shares (the “Shares”) of common stock, par value $0.01 per share, of the Company (“Common Stock”), at an offering price of $0.381 per share, and Series B Warrants to purchase 13,123,360 shares of Common Stock at an exercise price of $0.47 per share. The Shares were offered by the Company pursuant to a registration statement on Form S-3 (File No. 333-205545), which was filed with the Securities and Exchange Commission (the “Commission”) on July 8, 2015, and was declared effective by the Commission on July 20, 2015 (the “Registration Statement”). In a concurrent private placement (the “Private Placement”), the Company agreed to issue to the Investors Series A Warrants and Series C Warrants, each exercisable for 13,123,360 shares of Common Stock at an exercise price of $0.47 per share.

In conducting the Public Offering and Private Placement the Company carefully considered the availability of an exemption under Section 4(a)(2) of the Securities Act from the registration requirements of Section 5 of the Securities Act for the offer and sale of the Series A Warrants and Series C Warrants. In this analysis the Company relied on the guidance set forth in Staff’s Compliance and Disclosure Interpretations, Securities Act Sections, Question and Answer 139.25 and in Securities Act Release No. 8828 (August 3, 2007) concerning integration issues implicated by concurrent public and private offerings of securities (the “Interpretative Guidance”).  Under the Interpretative Guidance it is clear that an issuer may conduct concurrent public and private offerings of securities, but only if the issuer is able to establish that the investors in the private offering were not solicited by means of general solicitation (including through the filing of the Shelf Registration Statement).

Securities Act Release No. 8828 (August 3, 2007) provides some examples of the application of this analysis: “[I]f the prospective private placement investor became interested in the concurrent private placement through some means other than the registration statement that did not involve a general solicitation and otherwise was consistent with Section 4(2), such as through a substantive, pre-existing relationship with the company or direct contact by the company or its agents outside of the public offering effort, then the prior filing of the registration statement generally would not impact the potential availability of the Section 4(2) exemption for that private placement and the private placement could be conducted while the registration statement for the public offering was on file with the Commission. Similarly, if the company is able to solicit interest in a concurrent private placement by contacting prospective investors who (1) were not identified or contacted through the marketing of the public offering and (2) did not independently contact the issuer as a result of the general solicitation by means of the registration statement, then the private placement could be conducted in accordance with Section 4(2) while the registration statement for a separate public offering was pending.”

All potential investors in the Public Offering and Private Placement were solicited by means of direct contact by Ladenburg Thalmann & Co. Inc. (the “Placement Agent”), which was engaged as the Company’s placement agent pursuant to the terms of an engagement letter dated July 1, 2015 by and among the Company and the Placement Agent. The Placement Agent had a substantive pre-existing relationship with each of the investment managers for the Investors as a result of previous investments through the Placement Agent and previous contacts in connection with other potential investments. The Placement Agent or an affiliate thereof has confirmed to us that (i) it has had a relationship with the investment managers for the Investors since at least 2010, and (ii) it did not engage in any form of general solicitation or general advertising (as those terms are used in Regulation D under the Securities Act) in connection with the offer or sale of the Series A Warrants and Series C Warrants.

Ms. Amanda Ravitz

Securities and Exchange Commission

October 20, 2015

Page Two

Therefore, consistent with the Interpretative Guidance, the investors in the Private Placement became interested in the Private Placement through some means other than the Shelf Registration Statement that did not involve a general solicitation. Additionally, each Investor represented that at the time such Investor was offered the Series A Warrants and Series C Warrants and as of the date of executing the Securities Purchase Agreement, it was, and on each date on which it exercises any of the Series A Warrants and Series C Warrants, it will be either: (a) an “accredited investor” as defined in Rule 501(a)(1), (a)(2), (a)(3), (a)(7) or (a)(8) under the Securities Act or (b) a “qualified institutional buyer” as defined in Rule 144A(a) under the Securities Act; (ii) it acquired the Series A Warrants and Series C Warrants as principal for its own account and had no direct or indirect  arrangement or understandings with any other persons to distribute or regarding the distribution of such securities; (iii) such Investor, either alone or together with its representatives, had such knowledge, sophistication and experience in business and financial matters so as to be capable of evaluating the merits and risks of the prospective investment, and has so evaluated the merits and risks of such investment; and (iv) such Investor did not purchase the securities as a result of any advertisement, article, notice or other communication regarding the securities published in any newspaper, magazine or similar media or broadcast over television or radio or presented at any seminar or any other general solicitation or general advertisement. Each Series A Warrant and Series C Warrant were issued with a legend similar to the following:

[NEITHER] THIS SECURITY [NOR THE SECURITIES INTO WHICH THIS SECURITY IS [EXERCISABLE]] HAS [NOT] BEEN REGISTERED WITH THE SECURITIES AND EXCHANGE COMMISSION OR THE SECURITIES COMMISSION OF ANY STATE IN RELIANCE UPON AN EXEMPTION FROM REGISTRATION UNDER THE SECURITIES ACT OF 1933, AS AMENDED (THE “SECURITIES ACT”), AND, ACCORDINGLY, MAY NOT BE OFFERED OR SOLD EXCEPT PURSUANT TO AN EFFECTIVE REGISTRATION STATEMENT UNDER THE SECURITIES ACT OR PURSUANT TO AN AVAILABLE EXEMPTION FROM, OR IN A TRANSACTION NOT SUBJECT TO, THE REGISTRATION REQUIREMENTS OF THE SECURITIES ACT AND IN ACCORDANCE WITH APPLICABLE STATE SECURITIES LAWS. THIS SECURITY [AND THE SECURITIES ISSUABLE UPON [EXERCISE] OF THIS SECURITY] MAY BE PLEDGED IN CONNECTION WITH A BONA FIDE MARGIN ACCOUNT WITH A REGISTERED BROKER-DEALER OR OTHER LOAN WITH A FINANCIAL INSTITUTION THAT IS AN “ACCREDITED INVESTOR” AS DEFINED IN RULE 501(a) UNDER THE SECURITIES ACT OR OTHER LOAN SECURED BY SUCH SECURITIES.

Accordingly, the Company believes the offer and sale of the Series A Warrants and Series C Warrants met all the necessary requirements to be exempt from registration pursuant to Section 4(a)(2) of the Securities Act and otherwise was consistent with Section 4(a)(2) of the Securities Act.

Very truly yours,

/s/ Ty Lombardi

Ty Lombardi

Vice President, Finance

CORRESP
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		CORRESP

Amedica Corporation

1885 West 2100 South

Salt Lake City, Utah 84119

October 15, 2015

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

Attention:

 Geoffrey D. Kruczek

Re: Amedica Corporation (the “Company”)

Registration Statement on Form S-3

File No. 333-207289

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 4:00 p.m., Washington, D.C. time on October 19, 2015, or as soon thereafter as is practicable.  Once the Registration Statement has been declared effective, please confirm orally that event with our counsel, Dorsey & Whitney LLP, by calling Sam Gardiner at (801) 933-7362.

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 staff comments and the declaration of effectiveness 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,

Amedica Corporation

By:

   /s/ Ty Lombardi

 Name:

  Ty Lombardi

 Title:

  Vice President Finance

Mail Stop 3030
October 13 , 2015

B. Sonny Bal , MD
President and Chief Executive Officer
Amedica  Corporation
1885 West 2100 South
Salt Lake City, Utah 84119

Re: Amedica Corporation
  Registration Statement on Form S-3
Filed  October 5 , 2015
  File No.  333-207289

Dear Dr. Bal:

This is to advise you that we have not reviewed and will not review your registration
statement .

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are  in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

In the event you request acceleration of the effective date of the pending regist ration
statement, please provide  a written statement from the company acknowledging 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 i n the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 a nd 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibiliti es under

B. Sonny Bal , MD
Amedica  Corporation
October 13 , 2015
Page 2

 the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the registered securities .

You may contact Geoff Kruczek  at (202) 551 -3641  with any questions.

Sincerely,

 /s/ Geoff Kruczek for

Amanda Ravitz
        Assistant Director
        Office of Electronics and Machinery

cc: Sam Gardiner , Esq.
 David Marx, Esq.

July 16 , 2015

Via e -mail
B. Sonny Bal, MD
President and Chief Executive Officer
Amedica Corporation
1885 West 2100 South
Salt Lake City, Utah 84119

Re:   Amedica Corp.
         Registration Statement on Form S -3
         Filed July 8 , 2015
         File No. 333 -205545

Dear Dr. Bal :

This is to advise you that we have not reviewed and will not review your registration
statement .

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 1933 and
all applicable Securities Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

In the event you request acceleration of the effective date of the pending registrati on
statement, please provide a written statement from the company acknowledging 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 wit h 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 th e filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 4 61 regarding requests for acceleration.  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation

B. Sonny Bal, MD
Amedica Corporation
July 16 , 2015
Page 2

 of the fact that those requesting acceleration are aware of their respective responsibilities u nder
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the registered securities.

You may contact Jay Mumford at 202 -551-3637  with any questions.

Sincerely,

 /s/ Jay Mumford for

 Amanda Ravitz
Assistant Director

cc: (via e -mail)   Jeanne Whalen , Esq.

CORRESP
1
filename1.htm

		2015.07.16_Correspond - S-3 Acceleration Report

Amedica Corporation

1885 West 2100 South

Salt Lake City, Utah 84119

July 16, 2015

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

Attention:

 Jay Mumford

Re: Amedica Corporation (the “Company”)

Registration Statement on Form S-3

File No. 333-205545

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 4:00 p.m., Washington, D.C. time on July 20, 2015, or as soon thereafter as is practicable.  Once the Registration Statement has been declared effective, please confirm orally that event with our counsel, Dorsey & Whitney LLP, by calling Sam Gardiner at (801) 933-7362.

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 staff comments and the declaration of effectiveness 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,

Amedica Corporation

By:

 /s/Ty Lombardi

 Name:

  Ty Lombardi

 Title:

  Vice President Finance

CORRESP
1
filename1.htm

Company Acceleration Request

 Amedica Corporation

1885 West 2100 South

 Salt Lake City, Utah 84119

 February 11, 2014

VIA EDGAR

 Securities and
Exchange Commission

 Division of Corporation Finance

 Mail Stop 3561

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention: Ted Moskovitz

Re:
 Amedica Corporation

 Registration Statement on Form S-1

 File No. 333-192232

 Request for Acceleration

Ladies and Gentlemen:

 Amedica Corporation, a Delaware corporation (the “Registrant”), hereby formally requests that the Registrant’s previous acceleration request dated February 7, 2014 be withdrawn.

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, the
Registrant hereby respectfully requests that the effective date of the above-captioned registration statement on Form S-1 (File No. 333-192232) be accelerated so that the registration statement may become effective at 5:00 p.m., Eastern time,
on February 12, 2014, or as soon thereafter as practicable, or at such later time as the Registrant may orally request via telephone call to the staff. This request for acceleration is subject, however, to your receiving a telephone call prior
to such time from our legal counsel, Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., confirming this request. The Registrant hereby authorizes each of Daniel T. Kajunski and Anthony E. Hubbard of Mintz, Levin, Cohn, Ferris, Glovsky and Popeo,
P.C., counsel to the Registrant, to make such request on its behalf.

 The Registrant hereby acknowledges that:

(i)
 should the U.S. Securities and Exchange Commission (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;

(ii)
 the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the
Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

(iii)
 the Registrant may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.

 Please call Daniel T. Kajunski (617-542-1715) or Anthony E. Hubbard
(617-542-1706) of Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., counsel to the Registrant, with any comments or questions regarding this matter.

 Very truly yours,

 Amedica Corporation

 By:

 /s/ Kevin Ontiveros

 Name: Kevin Ontiveros

 Title: Chief Legal Officer

cc:
 Securities and Exchange Commission

Amanda Ravitz, Assistant Director

Ted Mozkovitz

 Amedica Corporation

 Eric K. Olson

 Jay M. Moyes

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

Daniel T. Kajunski

Anthony E. Hubbard

Cooley LLP

Darren K. DeStefano

CORRESP
1
filename1.htm

Underwriters Acceleration Request

 February 11, 2014

 VIA ELECTRONIC SUBMISSION

 Securities and Exchange Commission

Mail Stop 3561

Division of Corporation Finance

 100 F Street, N.E.

 Washington, DC 20549

Attention: Ted Moskovitz

Re:
 Amedica Corporation

 Registration Statement Filed on Form S-1

 Registration No. 333-192232

Ladies and Gentlemen:

 In
connection with the above-captioned Registration Statement, we wish to advise that between January 29, 2014 and the date hereof 1,258 copies of the Preliminary Prospectus dated January 29, 2014 were distributed as follows: 1,258 to
institutional investors and 0 to prospective underwriters, dealers, individuals and others.

 We have been informed by the
participating underwriters that they will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 We hereby join in the request of the registrant that the effectiveness of the above-captioned Registration Statement, as amended, be accelerated to 5:00 p.m. Eastern Time, on Wednesday, February 12,
2014, or as soon thereafter as practicable.

 [signature page follows]

 Very truly yours,

JMP Securities LLC

 As representative of
the

 Underwriters

By:

 JMP Securities LLC

By:

 /s/ Stephen Ortiz

 Name: Stephen Ortiz

 Title: Managing Director

[SIGNATURE PAGE TO ACCELERATION REQUEST OF THE UNDERWRITERS]

CORRESP
1
filename1.htm

Acceleration Request - Company

 Amedica Corporation

1885 West 2100 South

 Salt Lake City, Utah 84119

 February 7, 2014

VIA EDGAR

 Securities and
Exchange Commission

 Division of Corporation Finance

 Mail Stop 3561

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention: Ted Moskovitz

Re:
 Amedica Corporation

 Registration Statement on Form S-1

 File No. 333-192232

 Request for Acceleration

Ladies and Gentlemen:

 Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Amedica Corporation, a Delaware corporation (the “Registrant”), hereby respectfully
requests that the effective date of the above-captioned registration statement on Form S-1 (File No. 333-192232) be accelerated so that the registration statement may become effective at 5:00 p.m., Eastern time, on February 11, 2014, or as
soon thereafter as practicable, or at such later time as the Registrant may orally request via telephone call to the staff. This request for acceleration is subject, however, to your receiving a telephone call prior to such time from our legal
counsel, Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., confirming this request. The Registrant hereby authorizes each of Daniel T. Kajunski and Anthony E. Hubbard of Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., counsel to the
Registrant, to make such request on its behalf.

 The Registrant hereby acknowledges that:

(i)
 should the U.S. Securities and Exchange Commission (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;

(ii)
 the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the
Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

(iii)
 the Registrant may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.

 Please call Daniel T. Kajunski (617-542-1715) or Anthony E. Hubbard
(617-542-1706) of Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., counsel to the Registrant, with any comments or questions regarding this matter.

 Very truly yours,

 Amedica Corporation

 By:

 /s/ Kevin Ontiveros

 Name: Kevin Ontiveros

 Title: Chief Legal Officer

cc:
 Securities and Exchange Commission

Amanda Ravitz, Assistant Director

Ted Mozkovitz

 Amedica Corporation

 Eric K. Olson

 Jay M. Moyes

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

Daniel T. Kajunski

Anthony E. Hubbard

Cooley LLP

Darren K. DeStefano

CORRESP
1
filename1.htm

Acceleration Request - Underwriters

 February 7, 2014

 VIA ELECTRONIC SUBMISSION

 Securities and Exchange Commission

Mail Stop 3561

Division of Corporation Finance

 100 F Street, N.E.

 Washington, DC 20549

Attention: Ted Moskovitz

Re:
 Amedica Corporation

 Registration Statement Filed on Form S-1

 Registration No. 333-192232

Ladies and Gentlemen:

 In
connection with the above-captioned Registration Statement, we wish to advise that between January 29, 2014 and the date hereof 1,258 copies of the Preliminary Prospectus dated January 29, 2014 were distributed as follows: 1,258 to
institutional investors and 0 to prospective underwriters, dealers, individuals and others.

 We have been informed by the
participating underwriters that they will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 We hereby join in the request of the registrant that the effectiveness of the above-captioned Registration Statement, as amended, be accelerated to 5:00 p.m. Eastern Time, on Tuesday, February 11,
2014, or as soon thereafter as practicable.

 [signature page follows]

 Very truly yours,

JMP Securities LLC

 As representative of
the

 Underwriters

By:

 JMP Securities LLC

By:

 /s/ Stephen Ortiz

 Name: Stephen Ortiz

 Title: Managing Director

[SIGNATURE PAGE TO ACCELERATION REQUEST OF THE UNDERWRITERS]

November 29 , 2013

Via E -mail
Eric K. Olson
Chief Executive  Officer
Amedica Corporation
1885 West 2011 South
Salt Lake City, UT 84119

Re: Amedica Corporation
Registration Statement on Form S -1
Filed November 08 , 2013
Amendment No. 1 to Registration Statement on Form S -1
Filed November 15, 2013
  File No. 333 -192232

Dear Mr. Olson :

We have reviewed your  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 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 these  comments, we may have  additional comments .

Eric K. Olson
Amedica Corporation
November 29 , 2013
Page 2

 Summary, page 1

1. We note your response to our prior comment number 4; however, it appears that your
conclusion about PEEK adverse event reports is extrapolated from other data and may
not actually reflect adverse events reported for PEEK.  Please revise or advise.

Market Opportunity, page 2

2. We note your response to prior comment number 7; however, it is unclear why you have
marked certain information “confident ial” which appears to be publicly available.  If this
information is not publicly available, please tell us whether it was commissioned for you.

Management’s Discussion and Analysis of Financial Condition and Results of Operations,  page
45

Results of Op erations, page 48

3. We see that a 36% decrease in research and development expense in the nine months
ended September 30, 2013 is primarily attributed to “a reduction in research and
development activities.”  In expanded disclosure, please describe the acti vities that were
reduced and describe the underlying business reasons for the reductions you identify.

Long -Lived Assets and Goodwill, page 56

4. We refer to your response to prior comment 14.  In light of the reported stockholders’
deficit, please clari fy in your disclosure how you define “carrying value” of your single
reporting unit for goodwill impairment testing purposes.

Financial Statements, page F -1

Consolidated Statements of Cash Flows, page F -6

5. Tell us where the notes to financial statements  fully describe the $8 million cash inflow
identified as proceeds from issuance of convertible debt and warrants in the nine months
ended September 30, 2013.

Common Stock Warrant Liability, page F -20

6. It appears that you sold additional common stock warra nts in August and September
2013 in connection with sales of Series F preferred stock.  Please make disclosure about
these warrants, including their terms and conditions, and the related accounting in the
notes to financial statements.

Eric K. Olson
Amedica Corporation
November 29 , 2013
Page 3

 Note 8. Equity, p age F -23

7. We refer to your response to prior comment 11.  Under the heading “Conversion,” please
disclose the currently applicable conversion rate for each series of preferred stock.

We urge all persons who are responsible for the accuracy and adequacy  of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s  disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending regist ration statement please provide  a written s tatement from the company
acknowledging 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 staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding reque sts for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securitie s Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effectiv e date of the
registration statement.

You may con tact Praveen Kartholy, Staff Accountant, at (202) 551 -3778  or Gary Todd,
Accounting Reviewer,  at (202) 551 -3605  if you have questions regarding comments on the
financial statements and related matters.  Please contact Ted Moskovitz at (202) 551 -3689  or me
at (202) 551 -3528  with any other questions.

Eric K. Olson
Amedica Corporation
November 29 , 2013
Page 4

 Sincerely,

 /s/ Amanda Ravitz

 Amanda Ravitz
Assistant Director

cc (vi a e-mail): Kevin Ontiveros – Chief Legal Officer, Amedica Corporation
   Daniel Kajunski – Mintz  Levin (outside counsel)

CORRESP
1
filename1.htm

SEC Response Letter

 Daniel T. Kajunski  |  617
348 1715  |  dkajunski@mintz.com

 One Financial Center

Boston, MA 02111

 617-542-6000

617-542-2241 fax

www.mintz.com

 FOIA CONFIDENTIAL TREATMENT REQUESTED

PURSUANT TO 17 C.F.R. § 200.83

BY AMEDICA CORPORATION

November 25, 2013

VIA EDGAR & FEDERAL EXPRESS

 United
States Securities and Exchange Commission

 Division of Corporation Finance

100 F Street, N.E.

 Washington, D.C. 20549

Attention: Amanda Ravitz, Assistant Director

Re:
Amedica Corporation

Form Registration Statement on Form S-1

File 333-192232

 Ladies and Gentlemen:

We are submitting this letter on behalf of Amedica Corporation (the “Company”) in response to comments from the staff (the
“Staff”) of the Securities and Exchange Commission (the “Commission”) received by letter dated October 21, 2013 (the “Comment Letter”) from Amanda Ravitz, Assistant Director, to Eric K. Olson,
the Company’s Chief Executive Officer, relating to the above-referenced registration statement on Form S-1 of the Company initially submitted with the Commission on September 24, 2013 on a confidential basis pursuant to Title I,
Section 106 of the Jumpstart Our Business Startups Act. The Company’s initial response letter dated November 8, 2013 (the “Initial Response Letter”) responding to the Staff’s comments in the Comment Letter was
filed with the Company’s first public filing of the above referenced registration statement (the “Registration Statement”) on November 8, 2013 and the Company has since filed Amendment No. 1 to the Registration
Statement on November 15, 2013 (“Amendment No. 1”).

 This letter is to supplementally advise the Staff on a
confidential basis the anticipated price range of the offering and to provide the Company’s responses to certain comments set forth in the Comment Letter that were not addressed in the Initial Response Letter based on this confidential
anticipated price range. For convenient reference, we have set forth below in italics each of the Staff’s comments set forth in the Comment Letter to which we are responding in this letter and have keyed the Company’s responses to the
numbering of the comments and the

 Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

BOSTON | LONDON | LOS ANGELES | NEW YORK |
SAN DIEGO | SAN FRANCISCO | STAMFORD | WASHINGTON

 FOIA CONFIDENTIAL TREATMENT REQUESTED

PURSUANT TO 17 C.F.R. § 200.83

BY AMEDICA CORPORATION

MINTZ, LEVIN, COHN, FERRIS, GLOVSKY AND POPEO, P.C.

 Securities and Exchange Commission

 November 25,
2013

 Page 2

headings used in the Comment Letter. All of the responses are based on information provided to Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C. by
representatives of the Company.

 We are providing by overnight delivery to Mr. Ted Moskovitz of the Staff five courtesy copies of
this letter.

 General

19.
Comment: Once an offering pricing range is available, please disclose the aggregate intrinsic value of all outstanding options based on the midpoint of the range.

RULE 83 CONFIDENTIAL TREATMENT REQUEST MADE BY AMEDICA CORPORATION; REQUEST NO. 2013.11.25.19.1.

Response: The Company notes its response to comment 20 below with respect to the anticipated price range for the offering. Based
on the anticipated price range discussed in comment 20 below, the Company will include the following disclosure in the pre-effective amendment to the Registration Statement that includes the price range in the paragraph after the table on page 62 of
Amendment No. 1 as follows:

 “The aggregate intrinsic value of all outstanding options as of September 30, 2013 was
approximately $[***], based on an assumed initial public offering price of $[***] per share (the midpoint of the price range set forth on the front cover page of this prospectus).”

20.
Comment: While we note that you have not granted employee stock options in recent periods, there are other measurements in your financial statements that are in-part dependent on the estimated fair value of
your common stock. According, please expand to provide a specific discussion of each key factor contributing to any significant difference between the estimated fair value of your common stock and the estimated offering price (or pricing range) for
the 12 months prior to the contemplated offering. Note that we are deferring final evaluation of share-based compensation and other common equity-linked valuations until the estimated offering price is specified and we may have further comments in
that regard when you file an amendment containing that information.

 RULE 83 CONFIDENTIAL TREATMENT REQUEST MADE BY
AMEDICA CORPORATION; REQUEST NO. 2013.11.25.20.1.

 Response: The Company supplementally advises the Staff on a
confidential basis that, after consultation with the underwriters, it currently anticipates that in a subsequent pre-effective amendment to the Registration Statement it will disclose an offering with a proposed price range of $[***] to $[***] per
share (the “Anticipated Price Range”),

 FOIA CONFIDENTIAL TREATMENT REQUESTED

PURSUANT TO 17 C.F.R. § 200.83

BY AMEDICA CORPORATION

MINTZ, LEVIN, COHN, FERRIS, GLOVSKY AND POPEO, P.C.

 Securities and Exchange Commission

 November 25,
2013

 Page 3

after giving effect to an anticipated reverse stock split of 1-for-[***] to be effected before the effectiveness of the Registration
Statement. On a pre-reverse stock split basis, the Anticipated Price Range equates to an offering price range of between $[***] to $[***] per share, which is [***] than the estimated fair value of the Company’s common stock of $1.00 per share
on June 19, 2012 and $0.68 per share as of December 31, 2012 and September 30, 2013. The Anticipated Price Range translates into a pre-offering equity valuation of the Company of between approximately $[***] million and $[***] million. The
Anticipated Price Range is based on existing conditions in the public capital markets for biomaterial and medical device companies, the Company’s financial position and prospects (assuming the completion of the offering), the market valuations
of comparable publicly traded companies and discussions with the underwriters regarding potential valuations for the Company.

 * * * * *

 FOIA CONFIDENTIAL TREATMENT REQUESTED

PURSUANT TO 17 C.F.R. § 200.83

BY AMEDICA CORPORATION

MINTZ, LEVIN, COHN, FERRIS, GLOVSKY AND POPEO, P.C.

 Securities and Exchange Commission

 November 25,
2013

 Page 4

When appropriate, the Company will provide a written request for acceleration of the effective date of the Registration Statement and will
include the requested “Tandy” language therein. The Company and the underwriters are aware of their respective obligations under Rules 460 and 461 regarding requesting acceleration of the effectiveness of the Registration Statement.

We hope that the above responses and the proposed revisions to the Registration Statement will be acceptable to the Staff. Please do not
hesitate to call Daniel T. Kajunski, Esq. or Anthony E. Hubbard, Esq. of this firm at (617) 542-6000 with any comments or questions regarding the Registration Statement and this letter. We thank you for your time and attention.

Sincerely,

/s/ Daniel T. Kajunski

Daniel T. Kajunski

cc:
Securities and Exchange Commission

 Amanda Ravitz, Assistant Director

Ted Moskovitz

 Praveen Kartholy

 Gary Todd

 Amedica
Corporation

 Eric Olson

Jay Moyes

 Kevin Ontiveros

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

Jonathan Kravetz, Esq.

 Anthony
Hubbard, Esq.

 Cooley LLP

Babak Yaghmaie, Esq.

 Darren
DeStefano, Esq.

 Ernst & Young LLP

David Hickox

 Howard Stoker

October 21, 2013

Via E -mail
Eric K. Olson
Chief Executive  Officer
Amedica Corporation
1885 West 2011 South
Salt Lake City, UT 84119

Re: Amedica Corporation
Draft Registration Statement on Form S -1
Filed September 24 , 2013
  CIK No. 0001269026

Dear Mr. Olson :

We have reviewed your draft 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 providing  the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is ap propriate, please tell us why in your response.

After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.

General

1. Please supplementally provide us with copies of all written communications, as defined
in Rule 405 under the Securities Act, that you, or anyone authorized to do so on your
behalf, present to potential investors in reliance on Section 5(d) of the Securities Act,
whether or not they retain copies of the communications.  Similarly, please
supplementally provide us with any research reports  about you that are published or
distributed in reliance upon Section 2(a)(3) of the Securities Act of 1933 added by
Section 105(a) of the Jumpstart Our Business Startups Act by any broker or dealer that is
participating or will participate in your offerin g.

Eric K. Olson
Amedica Corporation
October 21, 2013
Page 2

 Graphics

2. Please remove images of products which are merely in development and/or for which you
have not made any commercial sales.

Summary, page 1

3. Please explain what you mean when you say in the first paragraph that over 11,500 of
your spine pro ducts have been “successfully” implanted.

4. We note your disclosure that the rate of adverse events reported to the FDA for your
Valeo interbody spinal fusion devices is “significantly lower” than for PEEK devices.
Please provide copies of the sources you  used to calculate your rate of adverse events
reported to FDA, as well as the rate for PEEK.

5. If you choose to retain selective financial statement disclosure of your revenues in the
summary, please also provide the related net loss for the relevant perio ds.

6. Because  your non -Silicon Nitride products appear to represent a significantly larger
portion of your product revenues, please revise your summary to explain your other
products in more detail and explain why you have highlighted your Silicon Nitride
products so significantly.

Market Opportunity, page 2

7. Please provide objective third party support for each place where you discuss the
characteristics or statistical data regarding your industry and provide us with copies of the
industry reports and res earch studies cited throughout your prospectus, clearly marked to
support references made therein.  For each  report and study cited, tell us:  (1) whether the
study was financed or prepared by you or at your direction; (2) whether your officers or
director s have any relationship with the researching institution; (3) whether the study is
publically available; and (4) whether the you  received consent to use the study as
required by Rule 436 of the Securities Act of 1933.   We may  have additional comments
upon reviewing these material s.

Our Silicon Nitride Technology Platf orm, page 2

8. You appear to indicate that you believe your product is superior because it has the listed
characteristics; however, it is unclear whether competing products also have some or all
of these characteristics.  Please revise or advise.

Eric K. Olson
Amedica Corporation
October 21, 2013
Page 3

 Our St rategy, page 3

Develop Silicon Nitride for Total Joint Components, page 4

9. Refer to the third bullet point on page 4.  Explain what you mean by “confirm our
regulatory strategy in the United States with the FDA.”

Risk Factors, page 10

Risks Related to Our Capital Resources, page 17

10. Please quantify expected future capital funding needs for your planned near term
activities, including research , development and regulatory approval activities necessary to
bring each of your discussed product candidate s to market.

Capitalization, page 39

11. Tell us, with a view toward disclosure in your capitalization discussion, whether there are
any contingencies associated with the assumed conversion of the preferred stock upon
consummation of the offering.  For instance , tell us whether there are contingencies
related to the size of the offering, the offering price or the valuation assigned to the
company.

Management’s Discussion and Analysis of Financial Condition and Results of Operating, page
45

Product Revenue, p age 46

12. We note your disclosure that you believe that sales of your products will increase based
upon your marketing efforts.  Please discuss the basis for this statement, taking into
account that :  (1) your silicon nitride based products have had FDA appr oval since 2008,
and your other products may have had a longer approval time;  and (2) in light of your
existing indebtedness, you appear to be unable to increase you r current spending on
marketing.

Eric K. Olson
Amedica Corporation
October 21, 2013
Page 4

 Critical Accounting Policies and Estimates, page 55

Long -lived Assets and Goodwill, page 56

13. While we note that you recognized a significant impairment charge for intangible assets
during 2012, the remaining carrying amount of those assets continues to be significant to
your total assets.  Accordin gly, please provide critical accounting policy disclosure that
more fully describes the risk of future impairment.  For instance, describe the margin you
believe exists before you would be required to potentially measure and recognize an
additional impairm ent loss, describe how you arrive at estimates of future cash flows and
describe the key assumptions on which your determination of recoverability is based.
Clarify the extent of subjectivity and potential variability of the impairment evaluation in
your particular circumstances.

14. In light of the significant impairment recognized for intangible assets in the year ended
December 31, 2012, please describe to us the analysis you performed and the factors you
relied upon in concluding that there was no goodwil l impairment as of December 31,
2012.   Your response should fully describe how you applied the guidance from FASB
ASC 350 -20.  In that you report negative equity and disclose that you have a single
reporting unit, please be specific in describing how you considered the guidance
applicable to reporting units with negative carrying amounts.

15. We see your continued losses and a decrease in revenues in the first six months of 2013.
Please tell us whether you performed an interim goodwill impairment analysis as  of June
30, 2013.  If not, please describe to us the factors you considered in concluding t hat an
interim analysis was un necessary.

16. With respect to goodwill, please expand for the following matters to enhance your
disclosures regarding the potential fo r goodwill impairment.  In that regard, please
consider the following in expanded MD&A:
 Please fully describe the factors you considered in concluding that as of your most
recent evaluation that it was more likely than not that there was no goodwill
impair ment.  That is, describe the factors you considered in concluding that the
carrying amount of goodwill did not exceed its implied fair value.
 Describe the key methods and assumptions used and describe how the key
assumptions were determined.
 Describe the d egree of uncertainty associated with the key assumptions, including
reasonable specificity to the extent you have assumed improvements in your
operating results.
 Describe potential events and circumstances that could reasonably be expected to
affect the ke y assumptions.

Eric K. Olson
Amedica Corporation
October 21, 2013
Page 5

 Stock -Based Compensation Expense, page 57

17. Please tell us whether you have had any preliminary pricing discussions with your
underwriters.  If so, please tell us about the substance of those discussions and tell us
whether those discussions were considered in determining the estimated fair value of
your common stock.

18. With respect to the 2.4 million restricted stock units granted in February 2013, please
disclose the expected amount of the charge to earnings, assuming vesting conditions are
satisfied.

19. Once an offering pricing range is available , please disclose the aggregate intrinsic value
of all outstanding options based on the midpoint of the range.

20. While we note that you have not granted employee stock options in recent periods, there
are other measurements in your financial statements that  are in -part dependent on the
estimated fair value of your common stock.  According, please expand to provide a
specific discussion of each key factor contributing to any significant difference between
the estimated fair value of your common stock and the estimated offering price (or
pricing range) for the 12 months prior to the contemplated offering.   Note that we are
deferring final evaluation of share -based compensation and other common equity -linked
valuations until the estimated offering price is speci fied and we may have further
comments in that regard when you file an amendment containing that information.

Market Opportunity, page 65

21. Please tell us whether your interbody spinal fusion  products would have been suitable for
use in all 400,000 of the procedures  discussed here .  If not, please revise to explain how
this number is relevant to your business .

Limitations on Biomaterials used in Interbody Spinal Fusion Materials, page 66

22. Please explain to us the basis for your beliefs regarding other biomaterials listed in this
section.

Our Strategy, Page 72

Continue to Implement our Design and Build Program , page 72

23. Please explain the evaluation criteria used by surgeons participating in the program.

Eric K. Olson
Amedica Corporation
October 21, 2013
Page 6

 Apply our Silicon Nitride Technology Platform to Other Uses, page 72

24. In regards to your discussion of silicon nitride technology ’s adaptability  to hip and knee
implants, dental implants, and sports medicine and trauma products , please disclose
whether each of these products has been evaluate d by the FDA or in the field , and the
expected timeline for each product’s introduction into the marketplace.

Executive and Director Compensation, page 94

25. Please reconcile information contained in the Summary Compensation table on page 94
with the narrative information on approved salaries located in the first paragraph  on page
95.

Annual Cash Bonuses, page 95

26. We note that you seek to reward your executives’ achievement of key strategic and
business outcomes with cash bonuses.  In this regard, it appears that the bonuses may not
be purely d iscretionary.  Please disclose  your executives’ 2012 strategic and business
outcome bonus goals, or advise.

Financial Statements, page F -1

27. Please update the financial statements when required by Rule 8 -08 of Re gulation S -X.

Consolidated Statements of Cash Flows, page F -6

28. Please tell us how you determined that your disclosure about non -cash financing and
investing activities is complete.  As appropriate, please expand the disclosure at the
bottom of the cash fl ow statement or add disclosure that clearly references the required
information from the notes to financial statements.  Refer to FASB ASC 230 -10-50.

Note 1. Organization and Summary of Significant Accounting Policies, page F -7

Revenue Recognition, page F-9

29. Please expand to clarify how you apply each of the four general revenue recognition
criteria enumerated in the second sentence of your revenue policy in determining the
timing and amounts revenue.  Please also clarify how you actually apply each of th e
matters referred to in the third sentence of your disclosure and clarify how those matters
relate to the four general criteria cited in the second sentence.  It appears that similar
considerations apply to the revenue policy disclosures on pages 46 and 5 5 of MD&A.

30. Please clarify whether revenue polices for “spinal fusion devices” referred to in the first
sentence of your revenue policy disclosure differ from those for “spinal implants”

Eric K. Olson
Amedica Corporation
October 21, 2013
Page 7

 referred to in the last sentence of the disclosure.  If the fourth sentence of your disclosure
is describing how you apply the delivery criteria from the second sentence of your
disclosure, please revise to clarify.  It appears that you may need to reorganize the
revenue policy disclosure to better clarify your revenue po licies, how you apply those
policies and when you actually recognize revenue.  It appears that similar considerations
apply to the revenue policy disclosures on pages 46 and 55 of MD&A.

Long -lived Assets and Goodwill, page F -10

31. You disclose that you ha ve a single reporting unit and we see that you report a
stockholders’ deficit.  However, your accounting policy for goodwill impairment testing
describes the method applicable to reporting units where the carrying amount is greater
than zero.  Accordingly,  tell us how your goodwill impairment testing accounting policy
disclosure considers the method and guidance applicable to reporting units with zero or
negative carrying amounts.  Refer to FASB ASC 350 -20.

Note 7. Debt and Line of Credit, page F -17

New Bank Debt/Preferred Stock Warrant Liability, page F -19

32. Please expand to describe or to refer to description of the impact of the covenant
violations on the balance sheet classification of your debt at June 30, 2013.

33. We note your disclosure on pages F-22 and F -28 of significant assumptions used in
determining the estimated fair value of your common shares.  Here , or in MD&A, please
provide expanded narrative to more fully explain your modeling and to add context to the
disclosed assumptions.  For inst ance, please consider the following in expanded
narrative:
 Describe the two components of the hybrid model referred to in your disclosure,
describe why you selected those models and clarify how you weight the results of the
discounted cash flow and guideli ne company models.
 Clarify the nature of the assumptions applicable to each of the two components of
your modeling and describe how you arrive at those assumptions.
 Add sufficient context to explain the assumptions.  For instance, clarify why revenue
growt h rates range between 5.7% and 609% and why EBITDA margins range
between 28.9% and (9877)%.

Eric K. Olson
Amedica Corporation
October 21, 2013
Page 8

 Exhibits

Exhibit 23.1 Consent of Ernst & Young LLP

34. Please file a consent  from your independent accountants with your first public filing in
EDGAR.  Afterwards, to the extent there is a delay in requesting effectiveness of your
registration statement, or there is any change, other than typographical, made to the
financial state ments, or there have been intervening events since the prior filing that are
material to you, please provide a currently dated and signed consent from your
independent accountants with subsequent publicly filed amendments.

If you intend to respond to the se comments with an amended draft registration statement,
please submit it and any associated correspondence in accordance with the guidance we provide
in the Division’s October 11, 2012 announcement on the SEC website at
http://www.sec.gov/divisions/corpf in/cfannouncements/drsfilingprocedures101512.htm.

Please keep in mind that we may publicly post filing review correspondence in
accordance with our December