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Philip Rice


December 15 2020Chief Financial OfficerZivo Bioscience Inc2804 Orchard Lake RdSuite 202Keego Harbor MI 48320ReZivo Bioscience IncRegistration Statement on Form S-1December 9 2020File No 333-251221Dear

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Document on Subject : "Philip Rice"— Transcript:

1 December 15, 2020 Philip Rice Chief Fin
December 15, 2020 Philip Rice Chief Financial Officer Zivo Bioscience, Inc. 2804 Orchard Lake Rd. Suite 202 Keego Harbor, MI 48320 Re: Zivo Bioscience, Inc. Registration Statement on Form S-1 December 9, 2020 File No. 333-251221 Dear Mr. Rice:             This is to advise you that we have not reviewed and will not review your registrationstatement.             Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind youthat the company and its management are responsible for the accuracy and adequacy of theirdisclosures, notwithstanding any review, comments, action or absence of action by the staff.             Please contact Sincerely, Division of Corporation Finance Office of Manufacturing