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                          October 14, 2020

       Richard Toselli, M.D.
       President and Chief Executive Officer
       InVivo Therapeutics Holdings Corp.
       One Kendall Square, Suite B14402
       Cambridge, MA 02139

                                                        Re: InVivo Therapeutics
Holdings Corp.
                                                            Registration
Statement on Form S-1
                                                            Filed October 7,
2020
                                                            File No. 333-249353

       Dear Dr. Toselli:

              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 Deanna
Virginio at 202-551-4530 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Life Sciences
       cc:                                              Rosemary G. Reilly,
Esq.