October 4, 2024 Daniel T. Scavilla President and Chief Executive Officer Globus Medical Inc. 2560 General Armistead Avenue Audubon , Pennsylvania 19403-5214 Re: Globus Medical Inc. Form 10-K for Fiscal Year Ended December 31, 2023 File No. 001-35621 Dear Daniel T. Scavilla : We have completed our review of your filings. 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. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services