July 3, 2019

Stephen Randall
Chief Financial Officer
Titan Medical Inc.
170 University Avenue
Suite 1000
Toronto, Ontario, Canada
M5H 3B3

       Re: Titan Medical Inc.
           Draft Registration Statement on Form F-3
           Submitted June 4, 2019
           CIK No. 0000840551

Dear Mr. Randall:

       We have reviewed your draft 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 providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form F-3 submitted June 4, 2019

Fee Table, page 2

1.     Refer to the second sentence of note (1) to the fee table. Other than
securities covered by
       the operation of Rule 416 of the Securities Act of 1933, you must
specifically register the
       type and amount of each security you intend to register. Please confirm
that your fee table
       will include a good faith estimate of the maximum number of shares
issuable pursuant to
       the warrants. In addition, please revise to remove part (ii) of the
footnote as you may not
       register an indeterminate number of unspecified types of securities.
 Stephen Randall
FirstName LastNameStephen Randall
Titan Medical Inc.
Comapany NameTitan Medical Inc.
July 3, 2019
Page 2
July 3, 2019 Page 2
FirstName LastName
Prospectus Cover Page, page 3

2.       We note your disclosure that your Prospectus Supplement will set forth
whether the shares
         or warrants are being offered for cash. Refer to Form F-3 General
Instructions 1.B.1 and
         1.B.5 and provide us your analysis as to how your securities could be
offered other than
         for cash or revise your disclosure as appropriate.
Documents Incorporated by Reference, page 9

3.       It appears that certain of your filing date and Material Change Report
exhibit references
         may not reflect the correct filing dates and/or exhibits where the
Material Change Reports
         are filed. Please review your references carefully and revise as
necessary.
There can be no assurance as to the liquidity of the trading market..., page 10

4.       Revise your risk factor, as appropriate, to indicate whether you
intend to list the units that
         may be offered.
Limitations on Ownership of Securities, page 16

5.       Briefly indicate any limitations on the holding or voting of your
shares imposed by the
         Investment Canada Act (Canada) that are applicable to U.S. investors.
Use of Proceeds, page 21

6.       Given your lack of revenues and ongoing product development costs,
please revise here to
         discuss specifically your short and long term cash needs and related
matters, such as FDA
         submission status and related additional milestones in connection
therewith, or tell us
         where this is addressed in the disclosure that is incorporated by
reference.
General

7.       Please confirm your understanding that your Form F-3 eligibility will
be determined at the
         time of the public filing of your registration statement.
8.       At the date of your initial public filing of your registration
statement, please ensure that
         you meet the requirements of Generation Instruction 1.B.1 of Form F-3
or revise your
         filing to include the disclosures required by Instruction 7 to General
Instruction 1.B.5 of
         Form F-3, as appropriate.
 Stephen Randall
FirstName LastNameStephen Randall
Titan Medical Inc.
Comapany NameTitan Medical Inc.
July 3, 2019
Page 3
July 3, 2019 Page 3
FirstName LastName
        You may contact Tara Harkins at (202) 551-3639 or Kevin Kuhar,
Accounting Branch
Chief, at (202) 551-3662 if you have questions regarding comments on the
financial statements
and related matters. Please contact Tim Buchmiller at (202) 551-3635 or Amanda
Ravitz,
Assistant Director, at (202) 551-3412 with any other questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Electronics
and Machinery