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2007

ED IT ION

ALPHATEC SPINE, INC. CODE OF CONDUCT CERTIFICATION

I have read the Alphatec Spine, Inc. (the “Company”) 2007 Edition of the Code of Conduct (the "Code"). I have obtained an interpretation of any provision about which I had a question. I agree to abide by the provisions of the Code. Based on my review, I acknowledge that

_____

To the best of my knowledge, I am not in violation of, or aware of

any violation by others of, any provision contained in the Code;

OR

_____

I have made a full disclosure below of the facts regarding any

possible violation of the provisions set forth in the Code.

In addition, I understand that I am required to report any suspected or actual violation of the Code. I understand that I am required to cooperate fully with the Company in connection with the investigation of any suspected violation. I understand that my failure to comply with the Code or its procedures may result in disciplinary action, up to and including termination.

Signature:___________________________

Name (Please print): _______________________

Date:

____________________________

Disclosures (please list each item separately and add an additional page if required)

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