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                              April 27, 2020

       Liron Carmel
       Chief Executive Officer
       Medigus Ltd.
       Omer Industrial Park, No. 7A, P.O. Box 3030
       Omer 8496500, Israel

                                                        Re: Medigus Ltd.
                                                            Registration
Statement on Form F-3
                                                            Filed April 21,
2020
                                                            File No. 333-237774

       Dear Mr. Carmel:

               We have limited our review of your registration statement to the
issue we have addressed
       in our comment. In our comment, 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 comment applies 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 this comment, we may have additional comments.

       Registration Statement on Form F-3 filed April 21, 2020

       General

   1.                                                   You do not appear to be
eligible to omit the names of the selling securityholders prior to
                                                        effectiveness of the
registration statement. Please revise or advise. Refer to General
                                                        Instruction II.H to
Form F-3.
               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.
 Liron Carmel
Medigus Ltd.
April 27, 2020
Page 2

       Please contact Irene Paik at 202-551-6553 or Joseph McCann at
202-551-6262 with any
questions.



                                                        Sincerely,
FirstName LastNameLiron Carmel
                                                        Division of Corporation
Finance
Comapany NameMedigus Ltd.
                                                        Office of Life Sciences
April 27, 2020 Page 2
cc:       Shachar Hadar, Adv.
FirstName LastName