August 1, 2023

 

 

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, NE

Washington, D.C. 20549

Attention: Jimmy McNamara

 

 

	Requested Date:	August 3, 2023
	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. 333-273493) (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 U.S. Securities and Exchange Commission. The Company hereby authorizes each of Jeffrey H. Kuras and Isaac Pasha of Honigman LLP, counsel to the Company, to make such request on its behalf.

 

Please confirm the effectiveness of the Registration Statement with Jeffrey H. Kuras of Honigman LLP by telephone at (313) 465-7446 or Isaac Pasha of Honigman LLP by telephone at (313) 465-8138.

 

[Signature page follows]

 

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Sincerely,

Zivo Bioscience, Inc.

 

_/s/ Keith Marchiando         

Keith Marchiando

Chief Financial Officer