United States securities and exchange commission logo October 7, 2021 Terry M. Rich President and Chief Executive Officer Surgalign Holdings, Inc. 520 Lake Cook Road, Suite 315 Deerfield, Illinois 60015 Re: Surgalign Holdings, Inc. Registration Statement on Form S-3 Filed September 29, 2021 File No. 333-259893 Dear Mr. Rich: 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 Jeffrey Gabor at 202-551-2544 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Michael P. Heinz, Esq.