September 13, 2018

Philip M. Rice, II
Chief Financial Officer
Zivo Bioscience, Inc.
2804 Orchard Lake Rd., Suite 202
Keego Harbor, Michigan 48320

       Re: Zivo Bioscience, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed February 21, 2018
           Form 10-Q for the Quarterly Period Ended June 30, 2018
           Filed August 14, 2018
           File No. 000-30415

Dear Mr. Rice:

        We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. In our comment, we may ask you to
provide us
with information so we may better understand your disclosure.

       Please respond to the comment within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to the comment, we may have additional
comments.

Form 10-Q for the Quarterly Period Ended June 30, 2018

Condensed Consolidated Balance Sheet, page 4

1.     In your Form 10-K for the year ended December 31, 2017, you reported a
deferred finance
       cost asset of $3,877,801 and Convertible Debentures Payable of
$17,443,768. However,
       starting with your Form 10-Q for the six months ended June 30, 2018, you
now report
       zero for your deferred finance cost asset and lower Convertible
Debentures Payable of
       $13,565,967 as of December 31, 2017. Please address the following:
         Explain your basis for making these adjustments.
         Tell us whether the adjustments reflect your adoption of ASU 2015-03,
and if so, why
           it was adopted in the second quarter of 2018 rather than in the
first quarter of 2016
 Philip M. Rice, II
Zivo Bioscience, Inc.
September 13, 2018
Page 2
             when it was required.
             Tell us the technical guidance upon which you relied in making
these adjustments and
             related disclosures, including your consideration of ASC 250. In
particular, explain
             why your presentation did not clearly identify the amounts as
restated or that an error
             was corrected.
             In addition, explain to us your basis for allocating the cost of
issued warrants between
             the sale of common stock and the issuance of debt, as discussed on
pages 7 and 13.
             Tell us how you considered these adjustments in your effectiveness
conclusions as part
             of your evaluations of internal controls over financial reporting
and disclosure controls
             and procedures.
       In closing, 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.

       You may contact Frank Wyman at 202-551-3660 or Kevin Vaughn at
202-551-3494 with
any questions.



FirstName LastNamePhilip M. Rice, II                           Sincerely,
Comapany NameZivo Bioscience, Inc.
                                                               Division of
Corporation Finance
September 13, 2018 Page 2                                      Office of
Healthcare & Insurance
FirstName LastName