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May 7, 2024
Carlos Macau
Chief Financial Officer
HEICO CORP
3000 Taft Street
Hollywood , Florida 33021
Re:HEICO CORP
Form 10-K for the fiscal year ended October 31, 2023
File No. 001-04604
Dear Carlos Macau:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            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.
Form 10-K for the fiscal year ended October 31, 2023
Critical Accounting Estimates, page 44
1.In future filings, please enhance your disclosures to provide qualitative and quantitative
information necessary to understand the estimation uncertainty and the impact your
critical accounting estimates have had or are reasonably likely to have on your financial
condition and results of operations. In addition, discuss how much each estimate and/or
assumption has changed over a relevant period and the sensitivity of reported amounts to
the underlying methods, assumptions and estimates used. The disclosures should
supplement, not duplicate, the description of accounting policies or other disclosures in
the notes to the financial statements. Refer to Item 303(b)(3) of Regulation S-K and SEC
Release No. 33-8350.
Notes to Consolidated Financial Statements
4. Goodwill and Other Intangible Assets, page 85
2.Please disclose the weighted-average amortization period for your intangible assets
subject to amortization in total and by major intangible asset class. See ASC 350-30-50-

 FirstName LastNameCarlos Macau
 Comapany NameHEICO CORP
 May 7, 2024 Page 2
 FirstName LastName
Carlos Macau
HEICO CORP
May 7, 2024
Page 2
1(a)(3).
Schedule II - Valuation and Qualifying Accounts, page 127
3.We note that you partially attribute the increases in your allowance for doubtful accounts
and inventory valuation reserves to "addition from acquisitions." Tell us how your
accounting treatment complies with ASC 805-20-30-4, which indicates that acquirers
shall not recognize a separate valuation allowance as of the acquisition date for assets
acquired in a business combination that are measured at their acquisition-date fair values
because the effects of uncertainty about future cash flows are included in the fair value
measure. In doing so, tell us how you determined the acquisition-date fair values of
accounts receivable and inventory acquired in business combinations.
            In closing, 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.
            Please contact Charles Eastman at 202-551-3794 or Andrew Blume at 202-551-3254 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing