April 9, 2019

Benjamin Sexson
Chief Executive Officer
Monogram Orthopaedics, Inc.
53 Bridge Street, Unit 507
Brooklyn, New York, 11251

        Re: Monogram Orthopaedics, Inc.
            Offering Statement on Form 1-A
            Filed March 13, 2019
            File No. 024-10973

Dear Mr. Sexson:

       We have reviewed your offering 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 offering 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 offering statement and the
information you
provide in response to these comments, we may have additional comments.

Form 1-A filed March 13, 2019

Investors in this offering may not be entitled to a jury trial, page 11

1.     We note your disclosure in this risk factor that investors "should
consult legal counsel
       regarding the jury waiver provision before entering into the
subscription agreement."
       However, we note that section 9 of the subscription agreement states
that each party
       represents and warrants that it "has reviewed this waiver with its legal
counsel, and that it
       knowingly and voluntarily waives its jury trial rights following
consultation with legal
       counsel." Please revise to describe in an appropriate section of your
offering circular this
       representation and warranty included in the subscription agreement.
Provisions of Note in Our Subscription Agreement, page 16

2.     Section 9 of your subscription agreement appears to indicate that the
forum selection
       provision does not apply to actions arising under the federal securities
laws. If so, please
       revise page 16 of your offering circular to disclose that your exclusive
forum provision
 Benjamin Sexson
FirstName LastNameBenjamin Sexson
Monogram Orthopaedics, Inc.
Comapany NameMonogram Orthopaedics, Inc.
April 9, 2019
April 2 2019 Page 2
Page 9,
FirstName LastName
         does apply to actions arising under the federal securities laws. Also,
please tell us which
         exhibit represents the operating agreement mentioned on page 16.
Use of Proceeds to Issuer, page 17

3.       We note your disclosure on page 10 regarding investors paying the
purchase price for
         your shares by cancellation or conversion of indebtedness. Please
quantify the price per
         share that investors who cancel or convert debt as mentioned on page
10 will pay per
         share for the securities being offered in this transaction, and
highlight any difference in the
         price that other investors will pay. Also, tell us the portion of the
offering that would be
         sold if all eligible debt holders cancelled or converted their debt
for securities in this
         offering. In this regard, if your disclosures regarding the minimum
offering amount like
         on pages 24 and 25 are based on the assumption that there are no note
cancellations or
         conversions, please clarify those disclosures in context.
4.       We note exhibit 6.1 and your disclosure regarding accounts payable to
related parties like
         on page F-18. Please provide the disclosure required by instruction 2
to Form 1-A Part II
         Item 6. Also, ensure that the appropriate section of your offering
circular includes all
         disclosure required by Form 1-A Part II Items 10, 11 and 13, including
with regard to
         section 6(c) of exhibit 6.9.
The Company's Business, page 18

5.       Given the status of development of your product, please tell us the
basis for your
         statements on page 20 regarding the equipment being significantly
cheaper and your
         flexibility to discount. Also clarify which of the disclosed
capabilities and advantages of
         the product have been developed and objectively demonstrated, and
clarify any material
         disadvantages identified to date.
6.       Please tell us whether you commissioned any of the data cited in your
offering circular.
         We note for example the information on page 25.
Regulation, page 22

7.       Please reconcile the timeline disclosed in the last sentence in this
section with the timeline
         disclosed in the first sentence of the second bullet point on page 25,
particularly given the
         twelve months mentioned in the last bullet point on page 24.
Exhibits

8.       Please file, or tell us why you do not believe you are required to
file, the
         license agreement mentioned in the second risk factor on page 9, the
preemptive rights
         mentioned on page 11, the agreements mentioned in footnote (1) on page
29, the
         development and supply agreement mentioned in the third paragraph on
page 30, the
         warrants mentioned on pages 30 and F-18, and the notes mentioned on
page F-12 not
         identified in your exhibit index. Also, please tell us (1) the
authority on which you rely to
 Benjamin Sexson
Monogram Orthopaedics, Inc.
April 9, 2019
Page 3
       offer new, substituted or additional securities as indicated on page 13
of exhibit 4 and
       (2) whether the subscription agreement mentioned on page 16 is the same
document as the
       Series A Preferred Stock Purchase Agreement mentioned on page 16.
        We will consider qualifying your offering statement at your request. If
a participant in
your offering is required to clear its compensation arrangements with FINRA,
please have
FINRA advise us that it has no objections to the compensation arrangements
prior to
qualification.

        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. We also remind you that, following qualification of your
Form 1-A, Rule 257
of Regulation A requires you to file periodic and current reports, including a
Form 1-K which
will be due within 120 calendar days after the end of the fiscal year covered
by the report.

       You may contact Tara Harkins at 202-551-3639 or Lynn Dicker, Senior
Accountant, at
202-551-3616 if you have questions regarding comments on the financial
statements and related
matters. Please contact Thomas Jones at 202-551-3602 or Russell Mancuso, Branch
Chief, at
202-551-3617 with any other questions.



                                                             Sincerely,
FirstName LastNameBenjamin Sexson
                                                             Division of
Corporation Finance
Comapany NameMonogram Orthopaedics, Inc.
                                                             Office of
Electronics and Machinery
April 9, 2019 Page 3
cc:       Andrew Stephenson
FirstName LastName