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                           August 9, 2021

       Keith Valentine
       President and Chief Executive Officer
       SeaSpine Holdings Corp
       5770 Armada Drive
       Carlsbad, CA 92008

                                                        Re: SeaSpine Holdings
Corp
                                                            Registration
Statement on Form S-3
                                                            Filed August 5,
2021
                                                            File No. 333-258527

       Dear Mr. Valentine:

              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 Gary
Guttenberg at (202) 551-6477 with any questions.




                           Sincerely,


                           Division of Corporation Finance

                           Office of Life Sciences
       cc:                                              Patrick O'Malley