September
1, 2021
VIA EDGAR
U.S.
Securities and Exchange Commission
Division
of Corporation Finance
100 F.
Street, NE
Washington,
D.C. 20549
Attention: Gregory
Herbers
Re:
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.
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Sincerely,
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Zivo Bioscience,
Inc.
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By:
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/s/ Keith
Marchiando
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Keith
Marchiando
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Chief Financial
Officer
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cc:
Donald J. Kunz,
Honigman LLP
Emily J. Johns,
Honigman LLP