United States securities and exchange commission logo





                               February 9, 2021

       Anthony D'Adamio, Esq.
       Senior Vice President and General Counsel
       Bioventus Inc.
       4721 Emperor Boulevard, Suite 400
       Durham, North Carolina 27703

                                                        Re: Bioventus Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed February 4,
2021
                                                            File No. 333-252238

       Dear Mr. D'Adamio:

             We have reviewed your amended registration statement and have the
following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Amendment No. 1 to Form S-1 filed February 4, 2021

       Recent Developments
       Investment and Potential Acquisition, page 6

   1.                                                   We note the disclosure
added to page 6 regarding a convertible debt investment of $1.5
                                                        million related to a
potential acquisition transaction, the consideration for which could
                                                        total up to $100
million. Please revise your disclosure to provide the name of the Target
                                                        or tell us why you do
not believe the identity of the Target is material at this time. Also,
                                                        please revise your
disclosure to provide more specifics about the nature of the Target's
                                                        business.
       Consolidated Financial Statements, page F-1

   2.                                                   Please clarify for us
how the financial statement periods included in your registration
 Anthony D'Adamio, Esq.
Bioventus Inc.
February 9, 2021
Page 2
      statement are consistent. In this regard, it appears that you have
selected December 31 as
      your fiscal year-end; however, your interim financial statements appear
to be based on a
      specific day of the week (i.e., last Saturday in September). If you have
adopted a 52-53
      week calendar year, your fiscal year-end would vary each year based on
the specific day
      of the week chosen. Conversely, if you have adopted a calendar year
fiscal-year, your
      interim periods should be consistent with the last day of the quarter
(i.e., March 31, June
      30, September 30th). Please advise and revise your financial statements
accordingly.
       You may contact Christie Wong at 202-551-3684 or Angela Connell at
202-551-3426 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Laura Crotty at 202-551-7614 or Tim Buchmiller at 202-551-3635 with any
other
questions.



                                                            Sincerely,
FirstName LastNameAnthony D'Adamio, Esq.
                                                            Division of
Corporation Finance
Comapany NameBioventus Inc.
                                                            Office of Life
Sciences
February 9, 2021 Page 2
cc:       Wesley C. Holmes, Esq.
FirstName LastName