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                         October 22, 2020

       Gary S. Gillheeney, Sr.
       President and Chief Executive Officer
       Organogenesis Holdings Inc.
       85 Dan Road
       Canton, MA 02021

                                                        Re: Organogenesis
Holdings Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed October 16,
2020
                                                            File No. 333-249531

       Dear Mr. Gillheeney:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.

                                                        Please contact Abby
Adams at (202) 551-6902 with any questions.




                         Sincerely,


                         Division of Corporation Finance

                         Office of Life Sciences
       cc:                                              Stacie S. Aarestad,
Esq.