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.
 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.




FirstName LastNameBarry F. Cohen                          Sincerely,
Comapany NameAVRA Medical Robotics, Inc.
                                                          Division of
Corporation Finance
June 27, 2019 Page 2                                      Office of Electronics
and Machinery
FirstName LastName