September 1, 2021
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, NE
Washington, D.C. 20549
Attention: Gregory Herbers
Zivo Bioscience, Inc.
Registration Statement on Form S-3
File No. 333-259082
Acceleration Request
Requested Date:    September 3, 2021
Requested Time:   4:00 P.M. Eastern Time
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, Zivo Bioscience, Inc. (the “Company”) hereby respectfully requests that the above-referenced Registration Statement on Form S-3 (File No. 333-259082) (the “Registration Statement”) be declared effective at the “Requested Date” and “Requested Time” set forth above, or as soon as practicable thereafter, or at such later time as the Company or its counsel may orally request via telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange Commission. The Company hereby authorizes each of Donald J. Kunz and Emily J. Johns of Honigman LLP, counsel to the Company, to make such request on its behalf.
Please confirm the effectiveness of the Registration Statement with Emily J. Johns of Honigman LLP by telephone at (616) 649-1908.


Zivo Bioscience, Inc.


/s/ Keith Marchiando
Keith Marchiando 
Chief Financial Officer 
Donald J. Kunz, Honigman LLP
Emily J. Johns, Honigman LLP