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United States securities and exchange commission logo
December 1, 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
Response Dated
November 27, 2023
File No. 001-34634
Dear Brian M. Bonnell:
We have reviewed your November 27, 2023 response to our comment
letter and have the
following comment.
Please respond to this letter within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this letter, we may have
additional comments. Unless
we note otherwise, any references to prior comments are to comments in
our October 25, 2023
letter.
Form 10-K for the fiscal year ended December 31, 2022
Consolidated Financial Statements
Note 1. Revenue Recognition, page 73
1. We have reviewed your
proposed revised disclosure and response to prior comment 1, and
we do not see in the
proposed disclosure the judgments made in the application of ASC
606. Please revise your
disclosure to identify and explain the judgments and changes in
judgments made in
applying ASC 606, and also provide the related qualitative and
quantitative
information, to more fully address the disclosure requirements of ASC 606-
10-50-1(b), 50-17(b),
and 50-20(a). Alternatively, describe to us the reasons why further
disclosure is not
necessary. Please provide us the calculations used to determine variable
consideration for the
periods presented so that we are able to better understand your
application of the ASC
606 disclosure requirements.
Brian M. Bonnell
ICU Medical, Inc.
December 1, 2023
Page 2
Please contact Michael Fay at 202-551-3812 or Brian Cascio at
202-551-3676 if you
have questions regarding comments on the financial statements and related
matters.
Sincerely,
FirstName LastNameBrian M. Bonnell
Division of
Corporation Finance
Comapany NameICU Medical, Inc.
Office of Industrial
Applications and
December 1, 2023 Page 2 Services
FirstName LastName