United States securities and exchange commission logo December 15, 2023 Brian M. Bonnell Chief Financial Officer ICU Medical, Inc. 951 Calle Amanecer San Clemente, CA 92673 Re: ICU Medical, Inc. Form 10-K for the fiscal year ended December 31, 2022 File No. 001-34634 Dear Brian M. Bonnell: We have completed our review of your filing. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services