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,
Statement on Form S-4
                                                            Filed March 13,
                                                            File No. 333-270482

       Dear Daniel Scavilla:

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

               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.


                           Division of Corporation Finance

                           Office of Industrial Applications and

       cc:                                              Jennifer Porter, Esq.