November 26, 2018 Philip M. Rice, II Chief Financial Officer Zivo Bioscience, Inc. 2804 Orchard Lake Rd., Suite 202 Keego Harbor, Michigan 48320 Re: Zivo Bioscience, Inc. Form 10-K for the Fiscal Year Ended December 31, 2018 Filed February 21, 2018 File No. 000-30415 Dear Mr. Rice: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Healthcare & Insurance