United States securities and exchange commission logo

                          November 17, 2022

       Richard Toselli
       President and Chief Executive Officer
       InVivo Therapeutics Holdings Corp.
       One Kendall Square, Suite B14402
       Cambridge, MA 02139

                                                        Re: InVivo Therapeutics
Holdings Corp.
Statement on Form S-1
                                                            Filed November 9,
                                                            File No. 333-268256

       Dear Richard Toselli:

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

               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 Jordan
Nimitz at 202-551-5831 with any questions.


                          Division of Corporation Finance

                          Office of Industrial Applications and

       cc:                                              Rosemary G. Reilly,