United States securities and exchange commission logo January 5, 2021 Jonathon M. Singer Chief Financial and Operating Officer Surgalign Holdings, Inc. 520 Lake Cook Road, Suite 315 Deerfield, IL 60015 Re: Surgalign Holdings, Inc. Registration Statement on Form S-1 Filed December 30, 2020 File No. 333-251828 Dear Mr. Singer: 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 David Gessert at 202-551-2326 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences