SecProbe.io

CORRESP
 1
 filename1.htm

 May 13, 2026

 VIA EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:
 SS INNOVATIONS INTERNATIONAL, INC.

 Registration Statement
on Form S-3 (File No. 333-295501)

 Request for Acceleration of Effective Date

 Requested Date: May 18, 2026

 Requested Time: 5:00 p.m. Eastern Time

 Ladies and Gentlemen:

 In accordance with Rule 461 under the Securities Act
of 1933, as amended, the undersigned hereby respectfully requests that the effective date of its Registration Statement on Form S-3, as
amended, (File No. 333-295501) be accelerated so that the same will become effective at 5:00 p.m., Eastern Time, on May 18, 2026, or as
soon thereafter as is practicable.

 If you have any questions regarding this request, please
contact our counsel Dale Bergman of Lewis Brisbois Bisgaard & Smith LLP at 954.302.4162.

 Very Truly Yours,

 SS INNOVATIONS INTERNATIONAL, INC.

 By:
 /s/ Sudhir Srivastava

 Name: Dr. Sudhir Srivastava Title: Chairman and Chief Executive Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 8, 2026

Sudhir Prem Srivastava
Chief Executive Officer
SS Innovations International, Inc.
405, 3rd Floor, iLabs Info Technology Centre
Udyog Vihar, Phase III
Gurugram, Haryana 122016, India

 Re: SS Innovations International, Inc.
 Registration Statement on Form S-3
 Filed May 01, 2026
 File No. 333-295501
Dear Sudhir Prem Srivastava:
 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 Claudia Rios at 202-551-8770 with any questions.

 Sincerely,

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

July 9, 2019
Barry F. Cohen
Chief Executive Officer and Acting Chief Financial Officer
AVRA Medical Robotics, Inc.
3259 Progress Drive, Suite 112A
Orlando, Florida 32826
Re:AVRA Medical Robotics, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed April 16, 2019
File No. 333-216054
Dear Mr. Cohen:
            We have completed our review of your filings.  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.
Sincerely,
Division of Corporation Finance
Office of Electronics and Machinery

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AVRA MEDICAL ROBOTICS, INC.

3259 Progress Drive Suite 112A

Orlando, FL 32826

July 3, 2019

Via EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Mail Stop 3030

100 “F” Street, N.E.

Washington, D.C. 20549-3629

 Attention: Ms. Jeanne Bennett

Mr. Gary
Todd

 Re: AVRA Medical Robotics, Inc. (the “Company”)

Form 10-K for the Fiscal Year Ended December 31,
2018

Filed
April 16, 2019

File
No. 333-216054

Ladies and Gentlemen:

In response to the comment set forth in
the Staff’s letter dated June 27, 2019, we file herewith Form 10-K/A Amendment No. 1 to the Company’s 2018 Annual Report
on Form 10-K, in which we have revised Item 9A. Controls and Procedures as requested by the Staff.

If you have any further questions or comments,
kindly contact the undersigned at (407) 956-2250 or our counsel, Dale S. Bergman, Esq. of Gutiérrez Bergman Boulris, PLLC
at (305) 358-5100.

Very truly yours,

AVRA MEDICAL ROBOTICS, INC.

    By:
    /s/ Barry F. Cohen

    Barry F. Cohen

    Chief Executive Officer

June 27, 2019
Barry F. Cohen
Chief Executive Officer and Acting Chief Financial Officer
AVRA Medical Robotics, Inc.
3259 Progress Drive, Suite 112A
Orlando, Florida 32826
Re:AVRA Medical Robotics, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed April 16, 2019
File No. 333-216054
Dear Mr. Cohen:
            We have reviewed your filing and have the following comment.  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 comment within ten business days by providing the requested
information or advise 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 the Fiscal Year Ended December 31, 2018
Item 9A. Controls and Procedures, page 14
1.While it appears that you completed the required evaluation of disclosure controls and
procedures, it does not appear that you have completed the separate evaluation of internal
control over financial reporting.  Accordingly, please complete the evaluation of internal
control over financial reporting required by Exchange Act Rule 13a-15(c).   Upon
completion of that evaluation, please amend your Form 10-K to provide management’s
report on internal control over financial reporting required by Item 308 of Regulation S-
K.  You may provide an abbreviated amendment that includes a cover page, explanatory
note, the complete text of Item 9A, a signature page and the certification required by Item
601(b)(31) of Regulation S-K, including paragraphs 1,2, 4 and 5.

 FirstName LastNameBarry F. Cohen
 Comapany NameAVRA Medical Robotics, Inc.
 June 27, 2019 Page 2
 FirstName LastName
Barry F. Cohen
AVRA Medical Robotics, Inc.
June 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.
            You may contact Jeanne Bennett, Staff Accountant, at 202-551-3606 or Gary Todd,
Senior Accountant, at 202-551-3605 with any questions.

Sincerely,
Division of Corporation Finance
Office of Electronics and Machinery

CORRESP
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AVRA MEDICAL ROBOTICS, INC.

3259 Progress
Drive Suite 126

Orlando,
FL 32826

July 27, 2017

Via EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Mail Stop 3030

100 “F” Street, N.E.

Washington, D.C. 20549-3629

    Attention:

    Ms. Laurie Abbott

    Ms. Amanda Ravitz

    Ms. Julie Sherman

    Ms. Kate Tillan

Re:
AVRA Medical
Robotics, Inc.
(the “Company”)

Registration
Statement
on Form S-1,
as amended

File
No. 333-216054

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and
Regulations under the Securities Act of 1933, as amended, the Company respectfully requests that the effective date of the above-referenced
Registration Statement be accelerated so that it will become effective at 4:00 p.m. Eastern Time on Monday, July  31, 2017,
or as soon thereafter as practicable.

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

Very truly
yours,

AVRA
MEDICAL ROBOTICS, INC.

By: /s/
Barry F. Cohen

Barry
F. Cohen

Chief
Executive Officer

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AVRA MEDICAL ROBOTICS, INC.

3259 Progress
Drive Suite 126

Orlando,
FL 32826

July 26, 2017

Via EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Mail Stop 3030

100 “F” Street, N.E.

Washington, D.C. 20549-3629

    Attention:

    Ms. Laurie Abbott

    Ms. Amanda Ravitz

    Ms. Julie Sherman

    Ms. Kate Tillan

Re:
AVRA Medical
Robotics, Inc.
(the “Company”)

Registration
Statement
on Form S-1,
as amended

File
No. 333-216054

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and
Regulations under the Securities Act of 1933, as amended, the Company respectfully requests that the effective date of the above-referenced
Registration Statement be accelerated so that it will become effective at 4:00 p.m. Eastern Time on Monday, July May 31, 2017,
or as soon thereafter as practicable.

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

Very truly
yours,

AVRA
MEDICAL ROBOTICS, INC.

By: /s/
Barry F. Cohen

Barry
F. Cohen

Chief
Executive Officer

Mail Stop 3030

July 7 , 2017

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

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

Dear Mr. Cohen :

We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide  us with information so we
may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information.   If you do not believe our comments apply to your facts and
circumstances or d o not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.   Unless we note
otherwise, our references to prior comments are to comments in our March 13, 2017 letter.

Results of Operations, page 36

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

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

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

 Financial Statements

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

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

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

Note 12. Subsequent Events, page F -17

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

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

Sincerely,

 /s/ Amanda Ravitz

Amanda Ravitz
Assistant Director
Office of Electronics and Machinery

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

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AVRA MEDICAL ROBOTICS, INC.

3259 Progress
Drive Suite 126

Orlando,
FL 32826

June 20, 2017

Via EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Mail Stop 3030

100 “F” Street, N.E.

Washington, D.C. 20549-3629

    Attention:
    Ms. Laurie Abbott

    Ms. Amanda Ravitz

    Ms. Julie Sherman

    Ms. Kate Tillan

Re:  AVRA Medical
Robotics, Inc.

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

    Filed May 11, 2017

    File No. 333-216054

Ladies and Gentlemen:

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

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

Selling Shareholders,
page 20

Comment:

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

Response:

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

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

Securities and Exchange Commission

Division of Corporation Finance

June 20, 2017

Page 2

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

Financial Statements

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

Comment:

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

Response:

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

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

Comment:

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

Response:

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

Note 3. Research
Collaboration Agreement,
page F-10

Comment:

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

Response:

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

Securities and Exchange Commission

Division of Corporation Finance

June 20, 2017

Page 3

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

Very
truly yours,

AVRA
MEDICAL ROBOTICS, INC.

By:  /s/ Barry F. Cohen

Barry
F. Cohen

Chief
Executive Officer

Mail Stop 3030

June 2 , 2017

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

Re: AVRA Medical Robotics, Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed May 11 , 2017
  File No. 333-216054

Dear Mr. Cohen :

We have reviewed your amended registration statement  and have the following
comments .  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration stateme nt and the information you
provide in response to these  comments, we may have  additional comments.   Unless  we note
otherwise , our references to prior comments are to comments in our March 13, 2017 letter .

Selling Shareholders, pa ge 20

1. We note your response to our p rior commen t number 11.  A s an affiliate  of yours , it
appears tha t Mr. Cohen may have facilitated a distribution of shares by you without
registration to the refer enced “third parties ” as statutory underwriter.  Provide your
analysis of how sales to the th ird parties was not such a distribution , or provide additional
disclosure explaining  that these sales may not have been conducted in compliance with
Section 5 of the Securiti es Act of 1933.

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

 Financial Statements

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

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

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

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

Note 3. Research Collaboration Agreement, page F -10

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

You may contact Julie Sherman at (202) 551 -3640 or Kate Tillan, Assistant Chief
Accountant, at (202) 551 -3604 if  you have questions regarding comments on the financial
statements and related matters.  Please contact Laurie Abbott at (202) 551 -8071 or me at
(202)  551-3528 with any other questions.

Sincerely,

 /s/ A manda Ravitz

Amanda Ravitz
Assistant Director
Office of Electroni cs and Machinery

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

CORRESP
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AVRA MEDICAL ROBOTICS, INC.

3259 Progress Drive Suite 126

Orlando, FL 32826

May 11, 2017

Via EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Mail Stop 3030

100 “F” Street, N.E.

Washington, D.C. 20549-3629

 Attention: Ms. Laurie Abbott

Ms. Amanda
Ravitz

Ms. Julie
Sherman

Ms. Kate
Tillan

Re: AVRA
Medical Robotics, Inc.

Registration
Statement on Form S-1

Filed February
14, 2017

File No.
333-216054

Ladies and Gentlemen:

In response to the Staff’s letter
of March 13, 2017, AVRA Medical Robotics, Inc. (the “Company”) hereby files Amendment No. 1 to the Registration
Statement on Form S-1.

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

Prospectus Cover

Comment:

 1. Please include the dealer prospectus delivery obligation on the outside back cover of the prospectus.
See Item 502(b) of Regulation S-K.

Response:

In response to the Staff’s comment,
the requested disclosure regarding the dealer prospectus delivery obligation has been added to the outside back cover of the prospectus.

Prospectus Summary, page 2

Comment:

 2. Where you make qualitative statements, please identify the source of this information or characterize
the statement as management’s belief. We note, for example, your disclosure on page 2 regarding robot’s “improved
accuracy and visualization” that is “equal to or better than that of invasive surgery,” and collaboration between
humans and robots being “so difficult to design well”; on page 3 regarding “one of the most important technical
challenges”; and on page 31 regarding “some of the best robotic surgeons in the world,” “most respected
hospital names,” and “strong relationships.”

Securities and Exchange Commission

Division of Corporation Finance

May 11, 2017

Page 2

Response:

The disclosure throughout the prospectus,
including in the “Prospectus Summary” and “Proposed Business” sections, has been revised
to give effect to the Staff’s comments.

Comment:

 3. We note your reference to www.allaboutroboticsurgery.com. Please see footnote 41 and the related
text in Release 33-7856 (April 28, 2000) regarding your obligations when including web site addresses in your document, including
the obligation to file linked information.

Response:

The website
reference has been deleted in response to the Staff’s comment.

Comment:

 4. Since the global skin care market likely includes a wide variety of products and services, it is
unclear how your disclosure of its size provides meaningful information to investors about your proposed business. Please revise
or advise.

Response:

The disclosure has been revised to give
effect to the Staff’s comment.

Comment:

 5. Refer to the first full paragraph on page 3 and your preceding disclosure regarding the surgical
robotics industry. It is not clear how your anticipated product or service represents an “innovative approach” to this
field. In the following paragraph you assert that improvements in “motors, materials and high resolution imaging allow”
robotics in the treatment of damaged skin, but go on to state that you are not aware of a robotic product for skin repair. Please
revise to make clear what opportunity your anticipated product is expected to address and how you know that the improvements you
enumerate already allow for damaged skin treatment if there are no current products addressing this application

.

Response:

The Company has substantially revised the
disclosure as requested by the Staff.

Comment:

 6. In your discussion of the surgical robotics industry, revise to provide a clear picture of the
state of current technology, including the very limited use and application of “real-time imagining,” and risks involved.
Alternatively, you may choose to limit your discussion of those aspects of robotic treatment which would apply to your anticipated
market, so that you create a realistic picture of where your possible business fits within the universe of medical robotics.

Securities and Exchange Commission

Division of Corporation Finance

May 11, 2017

Page 3

Response:

The disclosure has been revised in response
to the Staff’s comment.

Risk Factors, page 6

We will require substantial additional
financing, page 7

Comment:

 7. Given your disclosure on page 32 regarding obtaining FDA
approval, please clarify your disclosure here stating “if any are mandated.”

Response:

We have clarified the disclosure as requested
by the Staff.

If we or our third-party manufacturers
or suppliers fail to comply, page 12

Comment:

 8. Please expand your disclosure regarding your third party manufacturers and suppliers to clarify
whether you have already established relationships or entered agreements with any such manufacturers or suppliers.

Response:

The risk factor disclosure has been revised
and expanded in response to the Staff’s comment.

The Jobs Act has reduced the information
that the Company is required to disclose, page 15

Comment:

 9. 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.

Response:

As of the date of this letter, there have
not been any written communications to potential investors, as defined in Rule 405. The Company will provide copies of any such
Rule 405 written communications used in the future to the Staff.

Determination of Offering Price, page
19

Comment:

 10. Please expand your disclosure to explain that you have arbitrarily determined an initial offering
price of your shares that will apply until your shares are quoted on the OTCQX or the OTCQB.

Securities and Exchange Commission

Division of Corporation Finance

May 11, 2017

Page 4

Response:

The disclosure has been revised and expanded
both in the section referred to and in the “Risk Factors” section to provide the disclosure requested by the Staff.

Selling Shareholders, page 20

Comment:

 11. Rather than referring to “various transactions,” specifically identify each transaction
in which selling shareholders received their shares and provide sufficient detail to establish the exemption upon which you relied
in issuing the securities to the holder.

Response:

The disclosure has been revised to specify
the specific transactions in which the shares being registered were issued.

Comment:

 12. Refer to the third paragraph on page 20. Please note that you must disclose all material relationships
you have had with the selling shareholders during the past three years, even if they involve rendering service in the ordinary
course of business. Please revise.

Response:

The material
relationships have been set forth in the revised disclosure in response to the Staff’s comment.

Comment:

 13. Please revise your selling shareholders table to list the actual holder of the shares, even if
such shareholder in an entity. In this regard, we note the entities listed in footnotes 1–18 to this table. If any persons
who have control over the selling shareholder entities have held any position or office with you or have had any other material
relationship with you within the past three years, please provide the Regulation S-K Item 507 disclosure with respect to those
control persons. For guidance, refer to Regulation S-K Compliance and Disclosure Interpretation 140.02, available on the Commission’s
website.

Response:

The selling shareholders table has been
revised as requested by the Staff.

Comment:

 14. Please include a column in your selling shareholders table indicating the percentage, if greater
than one percent, of the class to be owned by each shareholder after completion of the offering. See Item 507 of Regulation S-K.

Response:

The requested additional column has been
added to the selling shareholders table in accordance with Item 507 of Regulation S-K.

Securities and Exchange Commission

Division of Corporation Finance

May 11, 2017

Page 5

Proposed Business, page 26

Comment:

 15. We note your disclosure regarding your team “bring[ing] the necessary resources, including
intellectual property,” to develop and commercialize your intended products. Please disclose the nature of such intellectual
property and other resources, clarify who owns them, and describe the material terms of any agreements pursuant to which you have
been authorized to use such intellectual property and other resources.

Response:

The disclosure both here and in the “Prospectus
Summary” section has been revised in response to the Staff’s comment.

Current Market, page 27

Comment:

 16. Please reconcile your disclosure in the fifth paragraph on page 27 that you are currently developing
a product for minimally invasive surgical  facial corrections with your disclosure in the second paragraph on page 28 that
your target market is the non-surgical segment of the skin resurfacing market.

Response:

The disclosure noted by the Staff has been
revised for consistency.

Efficiently to Market with a Superior
Solution, page 30

Comment:

 17. Please provide support for your statement that the cost of acquiring CO2 Lasers is higher than
your planned system. If you are relying on yours or third-party data to support this statement, please indicate the source of that
data.

Response:

We have
revised the disclosure in response to the Staff’s comment.

Comment:

 18. We note your disclosure in the first bullet point on page 31 that all elements of your robotic
device have been designed. However, from your current disclosure, it is unclear what your product is and how it will achieve your
intended results. Accordingly, please more thoroughly describe your “treatment delivered by a robotic device” and your
“planned technology.” Also clarify by what mechanism your device and technology will “improve[] the appearance
of skin.”

Response:

The referenced
disclosure has been clarified and expanded to give effect to the Staff’s comment.

Securities and Exchange Commission

Division of Corporation Finance

May 11, 2017

Page 6

Comment:

 19. Please expand your disclosure regarding the other users of your technology to identify the other
users and any relationship you have with them. Please also clarify whether you or the other users developed the technology, for
what applications the technology has received FDA 510(k) approval, and any licensing arrangements pursuant to which you and the
other users share this technology.

Response:

The disclosure
has been expanded and clarified as requested by the Staff.

Comment:

 20. Additionally, given that the technology has not yet received FDA approval as used in your product,
and because safety and efficiency are terms of art used in describing FDA clearances and approvals, please refrain from using these
terms in describing your product.

The Company has removed the terms referenced
in the Staff’s comment from the disclosure.

Comment:

 21. We note your disclosure in the first paragraph on page 31 regarding your ability to rapidly develop,
commercialize, and market your product. Please expand your disclosure to provide a clear indication of your business plan to achieve
commercialization and revenues. Your discussion should make clear what material steps are needed to achieve sales of your product,
your anticipated timeframe for seeking FDA approval, and your anticipated capital needs to complete each step.

Response:

We have expanded and clarified the disclosure
regarding the commercialization and FDA approval processes as requested by the Staff.

Comment:

Development Strategy, page 31

 22. Please expand your disclosure regarding your Research Agreement
with UCF to describe the “objectives as stated in the Statement of Work.”

Response:

We have provided the additional disclosure
regarding the Statement of Work requested by the Staff.

Market for Common Equity and Related
Shareholder Matters, page 34

Comment:

 23. Please provide the disclosure required by Item 201(a)(2)(i) of Regulation S-K. We note, for example,
the options issued to legal counsel disclosed on page F-12 and F-24.

Securities and Exchange Commission

Division of Corporation Finance

May 11, 2017

Page 7

Response:

The disclosure required by Item 201(a)(2)(i)
of Regulation S-K has been provided in a subsection entitled “Options, Warrants and Convertible Securities”
added to the referenced section of the Prospectus.

Management, page 30

Comment:

 24. Please ensure that you disclose all business experience of your directors and executive officers
during the past five years. In this regard, we note that Mr. Cohen has served as CEO of AVRA Surgical Robotics, Inc. since February
8, 2013, as indicated in the Form S-1 filed by AVRA Surgical Robotics, Inc. on February 12, 2013 and the website www.allaboutroboticsurgery.com.
Please also disclose Mr. Cohen’s directorship with AVRA Surgical Robotics, Inc. See Item 401(e)(2) of Regulation S-K. Similarly,
please expand your disclosure regarding Mr. Schauer’s business experience to describe his role as CFO of AVRA Surgical Robotics,
Inc. Please also include appropriate risk factor disclosure regarding Mr. Cohen and Mr. Schauer’s positions with other businesses.

Response:

The additional biographical information
requested by the Staff has been provided and the appropriate risk factor has been revised as requested by the Staff.

Executive Compensation, page 42

Comment:

 25. Please revise your summary compensation table so that options column discloses the aggregate grant
date fair value of the options computed in accordance with FASB ASC Topic 718 and the total column includes the value of the option
awards. See Item402(n)(2)(vi) and (x) of Regulation S-K.

Response:

The additional column has been added to
the summary compensation table to disclose the aggregate grant date fair value of the options.

Security Ownership of Certain Beneficial
Owners and Management, page 45

Comment:

 26. It appears that Avra Acquisitions, LLC owns 5% or more of your common stock. Accordingly, please
expand this table to include Avra Acquisitions, LLC as a separate shareholder. Please note that, in addition to separately disclosing
Avra Acquisitions, LLC’s shares, you should continue to include the shares of Avra Acquisitions, LLC among Mr. Cohen’s
holdings.

Response:

The principal
shareholders table has been expanded and revised in accordance with the Staff’s comments.

Securities and Exchange Commission

Division of Corporation Finance

May 11, 2017

Page 8

Financial Statements, page F-1

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

Comment:

 27. Please have your auditors revise the third paragraph of their opinion to state the period upon
which they are opining, which appears to be the period from inception to December 31, 2015.

Response:

The updated
auditors report included in the filing addresses the Staff’s comment.

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

Comment:

 28. We note that you also discuss a company called AVRA Surgical on the website www.allaboutroboticsurgery.com
which you reference in the overview section of the Form S-1. Please explain to us the relationship between these two companies
and whether the AVRA technology being used by AVRA Medical Robotics was initially developed by AVRA Surgical. Also include a chronology
of the development of the AVRA technology (the surgical robotic technology being used in your products) and the entities through
which it was developed.

Response:

The footnote has been revised in accordance
with the Staff. We do note that the reference to the website has been deleted in the instant filing.

Note 3. Research Collaboration Agreement,
page F-20

Comment:

 29. We note that you only include $8

Mail Stop 3030

March 13, 2017

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

Re: AVRA Medical Robotics, Inc.
Registration Statement on Form S-1
Filed February 14, 2017
  File No. 333-216054

Dear Mr. Cohen :

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 bel ieve 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.

Prospectus Cover

1. Please include the dealer prospectus delivery obligation on the outside back cover of the
prospectus.  See Item 502(b) of Regulation S -K.

Prospectus Summary, page 2

2. Where you make qualitative statements, please identify the source of this information or
characterize the statement as management’s belief.  We note, for example, your
disclosure on page 2 regarding robot’s “improved accuracy and visualization” that is
“equal to or better than that of invasive surgery,” and collaboration between humans and
robots being “so difficult to design well”; on page 3 regarding “one of the most important

Barry F. Cohen
AVRA Medical Robotics, Inc.
March 13, 2017
Page 2

 technical challenges”; and on page 31 regarding “some of the best robotic surgeons in the
world,” “most respected hospital names,” and “strong relationships.”

3. We note you r reference to www.allaboutroboticsurgery.com .  Please see footnote 41 and
the related text in Release 33 -7856 (April 28, 2000) regarding your obligations when
including web site addresses in your docum ent, including the obligation to file linked
information.

4. Since the global skin care market likely includes a wide variety of products and services,
it is unclear how your disclosure of its size provides meaningful information to investors
about your pr oposed business.  Please revise or advise.

5. Refer to the first full paragraph on page 3 and your preceding disclosure regarding the
surgical robotics industry.  It is not clear how your anticipated product or service
represents an “innovative approach” to  this field.  In the following paragraph you assert
that improvements in “motors, materials and high resolution imaging allow ” robotics in
the treatment of damaged skin, but go on to state that you are not aware of a robotic
product for skin repair.  Pleas e revise to make clear what opportunity your anticipated
product is expected to address and how you know that the improvements you enumerate
already allow for damaged skin treatment if there are no current products addressing this
application.

6. In your discussion of the surgical robotics industry, revise to provide a clear picture of the
state of current technology, including the very limited use and application of “real -time
imagining,” and risks involved.  Alternatively, you may choose to limit your di scussion
of those aspects of robotic treatment which would apply to your anticipated market, so
that you create a realistic picture of where your possible business fits within the universe
of medical robotics.

Risk Factors, page 6

We will require substan tial additional financing, page 7

7. Given your disclosure on page 32 regarding obtaining FDA approval, please clarify your
disclosure here stating “if any are mandated.”

If we or our third -party manufacturers or suppliers fail to comply, page 12

8. Please ex pand your disclosure regarding your third party manufacturers and suppliers to
clarify whether you have already established relationships or entered agreements with
any such manufacturers or suppliers.

Barry F. Cohen
AVRA Medical Robotics, Inc.
March 13, 2017
Page 3

 The Jobs Act has reduced the information that the Com pany is required to disclose, page 15

9. 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.

Determination of Offering Price, page 19

10. Please expand your disclosure to explain that you have arbitrarily determined an initial
offering price  of your shares that will apply until your shares are quoted on the OTCQX
or the OTCQB.

Selling Shareholders, page 20

11. Rather than referring to “various transactions,” specifically identify each transaction in
which selling shareholders received their sha res and provide sufficient detail to establish
the exemption upon which you relied in issuing the securities to the holder.

12. Refer to the third paragraph on page 20.  Please note that you must disclose all material
relationships you have had with the selli ng shareholders during the past three years, even
if they involve rendering service in the ordinary course of business.  Please revise.

13. Please revise your selling shareholders table to list the actual holder of the shares, even if
such shareholder in an entity.  In this regard, we note the entities listed in footnotes 1 –18
to this table.  If any persons who have control over the selling sh areholder entities have
held any position or office with you or have had any other material relationship with you
within the past three years, please provide the Regulation S -K Item 507 disclosure with
respect to those control persons.  For guidance, refer  to Regulation S -K Compliance and
Disclosure Interpretation 140.02, available on the Commission’s website.

14. Please include a column in your selling shareholders table indicating the percentage, if
greater than one percent, of the class to be owned by each  shareholder after completion of
the offering.  See Item 507 of Regulation S -K.

Proposed Business, page 26

15. We note your disclosure regarding your team “bring[ing] the necessary resources,
including intellectual property,” to develop and commercialize you r intended products.
Please disclose the nature of such intellectual property and other resources, clarify who
owns them, and describe the material terms of any agreements pursuant to which you
have been authorized to use such intellectual property and ot her resources.

Barry F. Cohen
AVRA Medical Robotics, Inc.
March 13, 2017
Page 4

 Current Market, page 27

16. Please reconcile your disclosure in the fifth paragraph on page 27 that you are currently
developing a product for minimally invasive surgical facial corrections with your
disclosure in the second paragraph on page 28 that your target market is the non-surgical
segment of the skin resurfacing market.

Efficiently to Market with a Superior Solution, page 30

17. Please provide support for your statement that the cost of acquiring CO 2 Lasers is higher
than your planned s ystem.  If you are relying on yours or third -party data to support this
statement, please indicate the source of that data.

18. We note your disclosure in the first bullet point on page 31 that all elements of your
robotic device have been designed.  However,  from your current disclosure, it is unclear
what your product is and how it will achieve your intended results.  Accordingly, please
more thoroughly describe your “treatment delivered by a robotic device” and your
“planned technology.” Also clarify by wha t mechanism your device and technology will
“improve[] the appearance of skin.”

19. Please expand your disclosure regarding the other users of your technology to identify the
other users and any relationship you have with them.  Please also clarify whether you or
the other users developed the technology, for what applications the technology has
received FDA 510(k) approval, and any licensing arrangements pursuant to which you
and the other users share this technology.

20. Additionally, given that the technology  has not yet received FDA approval as used in
your product, and because safety and efficiency are terms of art used in describing FDA
clearances and approvals, please refrain from using these terms in describing your
product.

21. We note your disclosure in th e first paragraph on page 31 regarding your ability to
rapidly develop, commercialize, and market your product.  Please expand your disclosure
to provide a clear indication of your business plan to achieve commercialization and
revenues.  Your discussion s hould make clear what material steps are needed to achieve
sales of your product, your anticipated timeframe for seeking FDA approval, and your
anticipated capital needs to complete each step.

Development Strategy, page 31

22. Please expand your disclosure regarding your Research Agreement with UCF to describe
the “objectives as stated in the Statement of Work.”

Barry F. Cohen
AVRA Medical Robotics, Inc.
March 13, 2017
Page 5

Market for Common Equity and Related Shareholder Matters, page 34

23. Please provide the disclosure required by Item 201(a)(2)(i) of Regulation S -K.  We note ,
for example, the options  issued  to legal counsel disclosed on page F -12 and F -24.

Management, page 30

24. Please ensure that you disclose all business experience of your directors and executive
officers during the past five years.  In this regard, w e note that Mr. Cohen has served as
CEO of AVRA Surgical Robotics, Inc. since February 8, 2013, as indicated in the Form
S-1 filed by AVRA Surgical Robotics, Inc. on February 12, 2013 and the website
www.allaboutroboticsurgery.com .  Please also disclose Mr.  Cohen’s directorship with
AVRA Surgical Robotics, Inc.  See Item 401(e)(2) of Regulation S -K.  Similarly, please
expand your disclosure regarding Mr.  Schauer’s business experience to describe his role
as CFO of AVRA Surgical Robotics, Inc.  Please also include appropriate risk factor
disclosure regarding Mr.  Cohen and Mr.  Schauer’s positions with other businesses.

Executive Compensation, page 42

25. Please revise your summary compensation table so that o ptions column discloses the
aggregate grant date fair value of the options computed in accordance with FASB ASC
Topic 718 and the total column includes the value of the option awards.  See Item
402(n)(2)(vi) and (x) of Regulation S -K.

Security Ownership o f Certain Beneficial Owners and Management, page 45

26. It appears that Avra Acquisitions, LLC owns 5% or more of your common stock.
Accordingly, please expand this table to include Avra Acquisitions, LLC as a separate
shareholder.  Please note that, in addi tion to separately disclosing Avra Acquisitions,
LLC’s shares, you should continue to include the shares of Avra Acquisitions, LLC
among Mr. Cohen’s holdings.

Financial Statements, page F -1

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

27. Please have your auditors revise the third paragraph of their opinion to state the period
upon which they are opining, which appears to be the period from inception to December
31, 2015.

Barry F. Cohen
AVRA Medical Robotics, Inc.
March 13, 2017
Page 6

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

28. We note that you also discuss a company called AVRA Surgical on the website
www.allaboutroboticsurgery.com  which you reference in the overview section of the
Form S -1.  Please explain to us the relation ship between these two companies and
whether the AVRA technology being used by AVRA Medical Robotics was initially
developed by AVRA Surgical.  Also include a chronology of the development of the
AVRA technology (the surgical robotic technology being used in your products) and the
entities through which it was developed.

Note 3. Research Collaboration Agreement, page F -20

29. We note that you only include $81,654 as research and development expense for the nine
months ended September 30, 2016.   Please tell us  how you have accounted for this
agreement, specifically how you determine the amount to record as research and
development expense and accrued liabilities each period.

Item 15. Recent Sales of Unregistered Securities, page II -1

30. Please provide the Regul ation S -K Item 701 disclosures for the issuance of options
disclosed in the last two paragraphs on page F -12.

Item 17.  Undertakings, page II -2

31. Please provide the undertakings required by Regulation S -K Item 512(a)(6).

Exhibits

32. Please file as exhibits the Indemnification Agreements disclosed on page F -12 and the
form of your 7.5% Convertible Promissory Note disclosed on page II -1.

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 acce leration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

Barry F. Cohen
AVRA Medical Robotics, Inc.
March 13, 2017
Page 7

 You may contact Julie Sherman at (202) 551 -3640 or Kate Tillan, Assistant Chief
Accountant, at (202) 551 -3604 if  you have questions regarding comments on the financial
statements and related matters.  Please contact Laurie Abbott at (202) 551 -8071 or me at
(202)  551-3528 with any other questions.

Sincerely,

 /s/ A manda Ravitz

Amanda Ravitz
Assistant Director
Office of Electroni cs and Machinery

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