United States securities and exchange commission logo August 19, 2022 Richard Toselli, M.D. President and Chief Executive Officer INVIVO THERAPEUTICS HOLDINGS CORP. One Kendall Square, Suite B14402 Cambridge, MA 02139 Re: INVIVO THERAPEUTICS HOLDINGS CORP. Preliminary Proxy Statement on Schedule 14A Filed July 8, 2022 File No. 001-37350 Dear Dr. Toselli: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Rosemary Reilly, Esq.