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                              November 24, 2020

       R. Kirk Huntsman
       Chief Executive Officer
       Vivos Therapeutics, Inc.
       9137 Ridgeline Boulevard, Suite 135
       Highlands Ranch, Colorado 80129

                                                        Re: Vivos Therapeutics,
Inc.
                                                            Amendment No. 2 to
Registration Statement on Form S-1
                                                            Filed November 19,
2020
                                                            File No. 333-249412

       Dear Mr. Huntsman:

             We have reviewed your amended registration statement and have the
following
       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.

       Amendment No. 2 to Registration Statement on Form S-1

       Prospectus Summary
       Overview, page 2

   1.                                                   We note your new
disclosure on page 2 indicating that the Vivos System led to lower
                                                        mean AHI scores by up
to 69.6% in patients with varying degrees of OSA as well as the
                                                        five studies cited in
your table and your statement that you are not aware of any additional
                                                        published studies that
evaluate the impact of the Vivos System on AHI scores in patients
                                                        with OSA.

                                                        We further note your
statement on page 1 indicating that there are 17 peer-reviewed
                                                        studies that examined
the impact of your "technologies and protocols" on the AHI scores
                                                        of patients with
varying degrees of OSA, that patient AHI scores were reduced from a low
 R. Kirk Huntsman
Vivos Therapeutics, Inc.
November 24, 2020
Page 2
      of 38% to a high of 98.6% and that you are not aware of any additional
published studies
      evaluating the impact of the Vivos System on AHI scores in patients with
OSA.

      Please revise your disclosure to reconcile your presentation of these
studies including
      whether "published studies" and "peer-reviewed studies" are terms for the
same type of
      study and, if not, the difference between a "published study" and a
"peer-reviewed" study.
Executive Compensation
October 2020 Derivative Demand and Settlement, page 107

2.    We note your statement that the Demanding Stockholders asked your board
of directors to
      review and investigate certain actions taken by your board of directors
and senior
      management, including actions related to the IPO, the rejection of a
transaction proposal,
      management of corporate assets and matters related to stock sales. We
further note your
      statement at the beginning of the following paragraph which refers to
"assertions" made
      by the Demanding Stockholders. Please revise your disclosure to clarify
what those
      "assertions" were.

      Please also file the Settlement and Release Agreement as an exhibit to
your registration
      statement or explain to us why it is not required to be filed.

      Finally, we note that your cross-references elsewhere in the document
state that this
      disclosure appears in the Business section. Please correct those
cross-references or move
      this disclosure to Business.
       You may contact Michael Fay at 202-551-3812 or Kevin Kuhar at
202-551-3662 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Alan Campbell at 202-551-4224 or Tim Buchmiller at 202-551-3635 with
any other
questions.



                                                           Sincerely,
FirstName LastNameR. Kirk Huntsman
                                                           Division of
Corporation Finance
Comapany NameVivos Therapeutics, Inc.
                                                           Office of Life
Sciences
November 24, 2020 Page 2
cc:       Lawrence A. Rosenbloom, Esq.
FirstName LastName