September 9, 2019

Gary S. Gillheeney
Chief Executive Officer
Organogenesis Holdings Inc.
85 Dan Road
Canton, MA 02021

       Re: Organogenesis Holdings Inc.
           Registration Statement on Form S-3
           Filed September 4, 2019
           File No. 333-233621

Dear Mr. Gillheeney:

       We have limited our review of your registration statement to those
issues we have
addressed in our comments. 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 registration statement
and providing the
requested information. 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 registration statement and the
information you
provide in response to these comments, we may have additional comments.

Registration Statement on Form S-3

General

1.     We note that your forum selection provision identifies the Court of
Chancery of the State
       of Delaware as the exclusive forum for certain litigation, including any
"derivative
       action." Please describe this provision and disclose whether this
provision applies to
       actions arising under the Securities Act or Exchange Act. In that
regard, we note that
       Section 27 of the Exchange Act creates exclusive federal jurisdiction
over all suits brought
       to enforce any duty or liability created by the Exchange Act or the
rules and regulations
       thereunder, and Section 22 of the Securities Act creates concurrent
jurisdiction for federal
       and state courts over all suits brought to enforce any duty or liability
created by the
       Securities Act or the rules and regulations thereunder. If the provision
applies to Securities
       Act claims, please also revise your prospectus to state that there is
uncertainty as to
 Gary S. Gillheeney
Organogenesis Holdings Inc.
September 9, 2019
Page 2
      whether a court would enforce such provision and that investors cannot
waive compliance
      with the federal securities laws and the rules and regulations
thereunder. If this provision
      does not apply to actions arising under the Securities Act or Exchange
Act, please also tell
      us how you will inform investors in future filings that the provision
does not apply to any
      actions arising under the Securities Act or Exchange Act.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Tonya K. Aldave at (202) 551-3601 or Dietrich King at
(202) 551-8071
with any questions.



                                                            Sincerely,
FirstName LastNameGary S. Gillheeney
                                                            Division of
Corporation Finance
Comapany NameOrganogenesis Holdings Inc.
                                                            Office of
Healthcare & Insurance
September 9, 2019 Page 2
cc:       William R. Kolb, Esq.
FirstName LastName