United States securities and exchange commission logo March 21, 2023 Daniel Scavilla Chief Executive Officer and President Globus Medical, Inc. 2560 General Armistead Avenue Audubon, PA 19403-5214 Re: Globus Medical, Inc. Registration Statement on Form S-4 Filed March 13, 2023 File No. 333-270482 Dear Daniel Scavilla: 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 Jane Park at 202-551-7439 with any questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services cc: Jennifer Porter, Esq.