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                              August 25, 2020

       Keith C. Valentine
       Chief Executive Officer
       SeaSpine Holdings Corporation
       5770 Armada Drive
       Carlsbad, CA 92008

                                                        Re: SeaSpine Holdings
Corporation
                                                            Registration
Statement on Form S-3
                                                            Filed August 19,
2020
                                                            File No. 333-248136

       Dear Mr. Valentine:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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 statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form S-3

       Item 16. Exhibits, page 20

   1.                                                   We note that the shares
were issued to the selling stockholder on July 28, 2020 and
                                                        August 17, 2020. Please
revise the legality opinion filed as Exhibit 5.1 to state that the
                                                        shares are legally
issued, fully paid and non-assessable. Refer to Section II.B.2.h of Staff
                                                        Legal Bulletin No. 19.
       General

   2.                                                   We note that your forum
selection provision identifies the Court of Chancery of the State
                                                        of Delaware as the
exclusive forum for certain litigation, including any    derivative
                                                        action.    Please
disclose whether this provision applies to actions arising under the
                                                        Securities Act or
Exchange Act. In that regard, we note that Section 27 of the Exchange
 Keith C. Valentine
SeaSpine Holdings Corporation
August 25, 2020
Page 2
      Act creates exclusive federal jurisdiction over all suits brought to
enforce any duty or
      liability created by the Exchange Act or the rules and regulations
thereunder, and Section
      22 of the Securities Act creates concurrent jurisdiction for federal and
state courts over all
      suits brought to enforce any duty or liability created by the Securities
Act or the rules and
      regulations thereunder. If the provision applies to Securities Act
claims, please also revise
      your prospectus to state that there is uncertainty as to whether a court
would enforce such
      provision and that investors cannot waive compliance with the federal
securities laws and
      the rules and regulations thereunder. If this provision does not apply to
actions arising
      under the Securities Act or Exchange Act, please tell us how you will
inform investors in
      future filings that the provision does not apply to any actions arising
under the Securities
      Act or Exchange Act.
        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.

       Please contact Ada D. Sarmento at 202-551-3798 or Celeste Murphy at
202-551-3257
with any questions.



                                                             Sincerely,
FirstName LastNameKeith C. Valentine
                                                             Division of
Corporation Finance
Comapany NameSeaSpine Holdings Corporation
                                                             Office of Life
Sciences
August 25, 2020 Page 2
cc:       Michael Kagnoff, Esq.
FirstName LastName