Ownership Submission
FORM 3
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

INITIAL STATEMENT OF BENEFICIAL OWNERSHIP OF SECURITIES

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934, Section 17(a) of the Public Utility Holding Company Act of 1935 or Section 30(h) of the Investment Company Act of 1940
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(Print or Type Responses)
1. Name and Address of Reporting Person *
  TULLIS JAMES L L
2. Date of Event Requiring Statement (Month/Day/Year)
03/08/2018
3. Issuer Name and Ticker or Trading Symbol
Alphatec Holdings, Inc. [ATEC]
(Last)
(First)
(Middle)
C/O ALPHATEC SPINE, INC., 5818 EL CAMINO REAL
4. Relationship of Reporting Person(s) to Issuer
(Check all applicable)
__X__ Director __X__ 10% Owner
_____ Officer (give title below) _____ Other (specify below)
5. If Amendment, Date Original Filed(Month/Day/Year)
(Street)

CARLSBAD, CA 92008
6. Individual or Joint/Group Filing(Check Applicable Line)
_X_ Form filed by One Reporting Person
___ Form filed by More than One Reporting Person
(City)
(State)
(Zip)
Table I - Non-Derivative Securities Beneficially Owned
1.Title of Security
(Instr. 4)
2. Amount of Securities Beneficially Owned
(Instr. 4)
3. Ownership Form: Direct (D) or Indirect (I)
(Instr. 5)
4. Nature of Indirect Beneficial Ownership
(Instr. 5)
Common Stock 51,564
D
 
Common Stock 1,239,985
I
By Tullis Dickerson Capital Focus III, LP (1)
Common Stock 900,734
I
By Tullis Growth Fund, L.P. (1)

Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly. SEC 1473 (7-02)
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Table II - Derivative Securities Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security
(Instr. 4)
2. Date Exercisable and Expiration Date
(Month/Day/Year)
3. Title and Amount of Securities Underlying Derivative Security
(Instr. 4)
4. Conversion or Exercise Price of Derivative Security 5. Ownership Form of Derivative Security: Direct (D) or Indirect (I)
(Instr. 5)
6. Nature of Indirect Beneficial Ownership
(Instr. 5)
Date Exercisable Expiration Date Title Amount or Number of Shares
Warrants (right to buy)   (2)   (2) Common Stock 36,675 $ 3.5 D  
6% Convertible Promissory Note due 2019 03/09/2019 03/09/2019 Common Stock 15,531 $ 3.22 D  
Warrants (right to buy)   (2)   (2) Common Stock 881,946 $ 3.5 I By Tullis Dickerson Capital Focus III, LP (1)
6% Convertible Promissory Note due 2019 03/09/2019 03/09/2019 Common Stock 373,493 $ 3.22 I By Tullis Dickerson Capital Focus III, LP (1)
Warrants (right to buy)   (2)   (2) Common Stock 640,651 $ 3.5 I By Tullis Growth Fund, L.P. (1)
6% Convertible Promissory Note due 2019 03/09/2019 03/09/2019 Common Stock 271,307 $ 3.22 I By Tullis Growth Fund, L.P. (1)

Reporting Owners

Reporting Owner Name / Address Relationships
Director 10% Owner Officer Other
TULLIS JAMES L L
C/O ALPHATEC SPINE, INC.
5818 EL CAMINO REAL
CARLSBAD, CA 92008
  X   X    

Signatures

/s/ James L.L. Tullis 03/12/2018
**Signature of Reporting Person Date

Explanation of Responses:

* If the form is filed by more than one reporting person, see Instruction 5(b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations. See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
(1) Reporting Person disclaims beneficial ownership of such shares except to the extent of his pecuniary interest therein.
(2) Each Warrant is exercisable for one share of the issuer's common stock for a period of five years following the date that stockholder approval is obtained.

Note: File three copies of this Form, one of which must be manually signed. If space is insufficient, See Instruction 6 for procedure.

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