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United States securities and exchange commission logo
March 1, 2022
Jamie Samath
Chief Financial Officer
INTUITIVE SURGICAL INC
1020 Kifer Road
Sunnyvale, CA 94086
Re: INTUITIVE SURGICAL
INC
10-K for the Fiscal
Year Ended December 31, 2021
Filed February 3,
2022
File No. 000-30713
Dear Mr. Samath:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comment. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this comment, we may have additional comments.
Form 10-K for the Year Ended December 31, 2021
Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
55
1. We note your disclosure
throughout the filing of your increased business level in China
through your majority
owned joint venture with Shanghai Fosun Pharmaceutical Group.
Please describe to us
and revise disclosure in future filings to include discussion and
analysis in
quantitative and qualitative terms related to your revenues that are
attributable
to China pursuant to
Item 303 of Regulation S-K, or explain to us why additional
disclosure is not
required. In addition, please explain to us whether there are any material
concentrations of
revenues included in "OUS" net sales in Note 5 to your financial
statements and describe
to us in further detail your methodology for attributing revenues
from external customers
to individual countries. Refer to ASC 280-10-50-41.
In closing, we remind
you that the company and its management are responsible for the
Jamie Samath
INTUITIVE SURGICAL INC
March 1, 2022
Page 2
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
You may contact Julie Sherman at (202) 551-3640 or Daniel Gordon, Senior
Advisor, at
(202) 551-3486 with any questions.
FirstName LastNameJamie Samath Sincerely,
Comapany NameINTUITIVE SURGICAL INC
Division of
Corporation Finance
March 1, 2022 Page 2 Office of Life
Sciences
FirstName LastName