January 31, 2020
Via E-mail

Richard C. Witzel, Jr., Esq.
Skadden, Arps, Slate, Meagher & Flom LLP
155 North Wacker Drive
Chicago, IL 60606

       Re:    Wright Medical Group N.V.
              Amendment No. 2 to Schedule TO-T
              Filed January 21, 2020
              File No. 005-86024

Dear Mr. Witzel:

       The staff in the Office of Mergers and Acquisitions has reviewed the
filing listed above,
and we have the comments set forth below. All defined terms used herein have
the same
meaning as in Offer to Purchase for Cash attached as Exhibit (a)(1)(A) to the
Schedule TO-T. In
some of our comments, we may ask you to provide us with information so we may
better
understand your disclosure.

       Please respond to this letter by amending your filing, by providing the
requested
information, or by advising us when you will provide the requested response. If
you do not
believe our comments apply to your facts and circumstances or do not believe an
amendment is
appropriate, please tell us why in your response.

       After reviewing any amendment to your filing and the information you
provide in
response to these comments, we may have additional comments.

Exhibit (a)(1)(A)

1. We note your response to comment 3, and particularly your representation
that, "[a]fter
   discussion with the Depositary, and reviewing other precedent transactions,
the Filing
   Persons believe that the contemplated timing for the acceptance for payment
and payment for
   Shares in the Offer falls within the bounds of customary practice of the
financial
   community." However, we are aware of recent precedent involving a
cross-border business
   combination with a target incorporated in the Netherlands whereby the
purchaser committed
   to prompt payment within three business days. Please expand upon your
response and
   supplement your disclosure to better explain why, in light of this recent
precedent, payment
   within four business days complies with the prompt payment provision of Rule
14e-1(c).
 Richard C. Witzel, Jr., Esq.
Skadden, Arps, Slate, Meagher & Flom LLP
January 31, 2020
Page 2

2. Your disclosure indicates that Purchaser will pay for all shares validly
tendered and not
   properly withdrawn pursuant to the Offer "as promptly as practicable." Rule
14e-1(c)
   requires that you pay the consideration offered "promptly" upon expiration
of the offer.
   Please revise here and throughout the document as needed.

                                              *   *   *

        We remind you that the registrant 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 direct any questions to me at (202) 551-7951. You may also
contact Tina Chalk,
Senior Special Counsel, at (202) 551-3263.


                                                            Sincerely,

                                                            /s/ Joshua Shainess

                                                            Joshua Shainess
                                                            Special Counsel
                                                            Office of Mergers
and Acquisitions