United States securities and exchange commission logo June 16, 2020 Peter Mariani Chief Financial Officer Axogen, Inc. 13631 Progress Boulevard, Suite 400 Alachua, FL 32615 Re: Axogen, Inc. Form 10-K for the Fiscal Year Ended December 31, 2019 Filed February 24, 2020 File No. 001-36046 Dear Mr. Mariani: We have completed our review of your filings. 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