Alphatec Holdings, Inc.
5818 El Camino Real
Carlsbad, CA 92008
May 9, 2018
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street N.E.
Washington, D.C. 20549
Attention: Tom Jones, Esq.
| RE: | Alphatec Holdings, Inc. |
Registration Statement on FormS-3
FileNo. 333-224304
REQUEST FOR ACCELERATION OF EFFECTIVENESS
Dear Mr. Jones:
Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Alphatec Holdings, Inc. (the “Registrant”) hereby requests acceleration of the effective date of its Registration Statement on FormS-3 (FileNo. 333-224304), as amended (the “Registration Statement”), so that it may become effective at 4:00 pm (EDT) Friday, May 11, 2018, or as soon as practicable thereafter. There are no underwriters of the issuance of the securities being registered.
We request that we be notified of such effectiveness by a telephone call to our outside counsel, Wayne Swan or Josh Little, of the law firm Durham, Jones & Pinegar, P.C., at (801)415-3000. We also respectfully request that a copy of the written order from the Commission verifying the effective time and date of such Registration Statement be sent to our outside counsel via facsimile at (801)415-3500, or by email: wswan@djplaw.com.
Sincerely yours,
Alphatec Holdings, Inc.
/s/ Jeffrey G. Black |
| Jeffrey G. Black, EVP and Chief Financial Officer |
