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                          August 31, 2021

       Keith Marchiando
       Chief Financial Officer
       Zivo Bioscience, Inc.
       2804 Orchard Lake Rd., Suite 202
       Keego Harbor, MI 48320

                                                        Re: Zivo Bioscience,
Inc.
                                                            Registration
Statement on Form S-3
                                                            Filed August 26,
2021
                                                            File No. 333-259082

       Dear Mr. Marchiando:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.

                                                        Please contact Gregory
Herbers at 202-551-8028 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Manufacturing
       cc:                                              Donald J. Kunz