TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo April 7, 2021 Patrick Miles Chief Executive Officer Alphatec Holdings, Inc. 1950 Camino Vida Roble Carlsbad, CA 92008 Re: Alphatec Holdings, Inc. Registration Statement on Form S-3 Filed March 31, 2021 File No. 333-254915 Dear Mr. Miles: 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 Dillon Hagius at 202-551-7967 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Matthew Bush