View:
January
14,
2008
United
States
Securities and Exchange Commission
Division
of
Corporation Finance
Mail
Stop
6010
100
F Street
NE
Washington,
DC 20549
Re: ICU
Medical, Inc.
Form
10-K for the Fiscal Year Ended December
31, 2006
File
No. 000-19974
This
letter
is in response to the Staff’s comment letter dated December 17,
2007.
Form
10-K
for the Fiscal Year Ended December 31, 2006
Consolidated
Balance Sheets, page 41
|
1.
|
Please
refer to prior comment 3. We note your response but do not
believe that using the term ‘highly liquid investments’ would provide
further clarification. It appears that your accounting policy
for this account is labeled ‘investment securities.’ To prevent
confusion regarding whether the amounts presented as ‘liquid investments’
are cash equivalents, please revise future filings so that the description
of the account is consistent with your terminology in the accounting
policies and with Item 5-02.2 of Regulation
S-X.
|
Response:
The
Company
will change the caption to “Marketable Securities” in future
filings.
Very
truly
yours,
/s/Francis
J. O’Brien
Francis
J.
O’Brien
Chief
Financial Officer