UNITED STATES
                                    SECURITIES AND EXCHANGE COMMISSION
                                                WASHINGTON, D.C. 20549


     DIVISION OF
CORPORATION FINANCE


                                                                  June 13, 2019

  By E-Mail

  Beth E. Berg, Esq.
  Sidley Austin LLP
  One South Dearborn
  Chicago, IL 60603

          Re:      MiMedx Group, Inc.
                   Definitive Additional Materials on Schedule 14A
                   Filed June 10, 2019
                   File No. 001-35887

  Dear Ms. Berg:

          We have reviewed your filing and have the following comment.

  1.      Each statement or assertion of opinion or belief must be clearly
characterized as such,
          and a reasonable factual basis must exist for each such opinion or
belief. Support for
          opinions or beliefs should be self-evident, disclosed in the proxy
statement or provided to
          the staff on a supplemental basis. With a view toward revised
disclosure, provide support
          for the following:

                that your investigation found evidence that demonstrated that
"Mr. Petit and certain
                members of his management team engaged in longstanding material
misconduct";

                that "the evidence demonstrated that Mr. Petit and certain
members of his
                management team disregarded accounting rules; undertook
improper actions to
                manage and manipulate the timing and recognition of revenue;
made misleading and
                false statements to the Company's outside auditors, the Board
and the U.S. Securities
                and Exchange Commission after questions were raised about the
Company's
                accounting practices; took actions against whistleblowers; and
emphasized short-term
                business goals over compliance and ethics"; and,

                your disclosure in each of the bullet points in the first and
second page of your press
                release.
 Beth E. Berg, Esq.
Sidley Austin LLP
June 13, 2019
Page 2

       Please direct any questions to me at (202) 551-3619.

                                                          Sincerely,

                                                          /s/ Daniel F.
Duchovny
                                                          Daniel F. Duchovny
                                                          Special Counsel
                                                          Office of Mergers and
Acquisitions