July 31, 2019
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F. Street N.E.
Washington, D.C. 20549
Attn: Mr. Tom Jones
| Re: | Alphatec Holdings, Inc. (ATEC) |
Registration Statement on FormS-3 |
FileNo. 333-232664 |
REQUEST FOR ACCELERATION OF EFFECTIVENESS |
Ladies and Gentlemen:
In accordance with Rule 461 under the Securities Act of 1933, as amended, Alphatec Holdings, Inc. (the “Registrant”) respectfully requests that the effective date of the above-referenced Registration Statement filed with the U.S. Securities and Exchange Commission (the “Commission”) be accelerated so that it may become effective at 5:00 p.m. (EST) on Friday, August 2, 2019, or as soon thereafter as practicable.
The Registrant also requests that it be notified of such effectiveness by a telephone call to its outside counsel, Joshua E. Little, of the law firm Durham Jones & Pinegar, P.C., at (435)674-0400, and that a copy of the written order from the Commission verifying the effective time and date of such Registration Statement be sent to its outside counsel via facsimile at (435)628-1610 or by email at jlittle@djplaw.com.
Sincerely,
Alphatec Holdings, Inc.
/s/ JEFFREY G. BLACK
Jeffrey G. Black
Chief Financial Officer
