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April 8, 2024
Brian G. Andrews
Executive Vice President, Chief Financial Officer and Treasurer
COOPER COMPANIES, INC.
6101 Bollinger Canyon Road, Suite 500
San Ramon, California 94583
Re:COOPER COMPANIES, INC.
Form 10-K for Fiscal Year Ended October 31, 2023
Filed December 8, 2023
Form 8-K Filed December 7, 2023
File No. 001-08597
Dear Brian G. Andrews:
            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 Fiscal Year Ended October 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Critical Accounting Estimates, page 53
1.The disclosures you have provided for each of your identified critical estimates appear to
provide investors with a discussion as to how you are accounting for these items in
accordance with US GAAP and are similar to your significant accounting policies
disclosures rather than providing investors with an understanding as to what the critical
estimates being made are and how the uncertainty associated with those estimates may
impact your consolidated financial statements. Please revise the disclosures for each of
your critical estimates made in preparing your consolidated financial statements to comply
with the guidance in Section 501.14 of the Financial Reporting Codification. Ensure your
disclosures sufficiently explain to investors what each critical estimate is; the uncertainties
associated with the critical estimates; the methods and assumptions used to make the
critical estimates, including an explanation as to how you arrived at the assumptions used;

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April 8, 2024
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the events or transactions that could materially impact the assumptions made; and how
reasonably likely changes to those assumptions could impact your consolidated financial
statements. Provide investors with quantified information to the extent meaningful and
available.
Consolidated Statements of Income, page 57
2.We note from your disclosures in Item 1. Business and from your revenue recognition
accounting policy that you offer products and services to your customers.  Please tell us
what consideration was given to separately presenting net sales and cost of sales from
products and from services. As part of your response, please provide us with such
information for the periods presented. Refer to Article 5-03(b)(1) and (2) of Regulation S-
X.
3.We note that you are presenting amortization of intangible separately and also presenting
a gross profit measure.  Please tell us your consideration of the guidance in SAB Topic
11:B and how you concluded that the gross profit measure is fully burdened.  As part of
your response, please confirm that you will expand your disclosures in Note 4 to clarify
what the composite intangible asset represents and why the components are not reflected
separately or within the corresponding categories already presented.
Note 1. Organization and Significant Accounting Policies
Revenue Recognition, page 63
4.We note that with the acquisition of Generate Life Sciences on December 17, 2021, you
began offering donor egg and sperm for fertility treatments, fertility cryopreservation
services and newborn stem cell storage (cord blood & cord tissue) services.  Please
expand your revenue recognition policy to provide the disclosures for revenues related to
the various services you provide including identification of the performance obligations
(i.e., when typically satisfied, significant payment terms, nature of goods and services,
obligations for returns, refunds, and other similar obligations, and types of warranties and
related obligations) with reference to ASC 606-10-50-12 and 50-12A, significant
judgments for the method used to recognize revenue over time and why the method
faithfully depicts the transfer of the services with reference to ASC 606-10-50-18, variable
consideration and any other obligations with reference to ASC 606-10-50-20.
Note 3. Acquisitions and Joint Venture
Joint Venture, page 70
5.We note that in connection with the sale of a 50% interest in SGV to Essilor in March
2022 for $52.1 million, the creation of a new joint venture in which each party contributed
their interest in SGV along with a $10 million cash payment, you remeasured the fair
value of your retained equity investment in the new joint venture at $90 million resulting
in the recognition of a $56.9 million gain.  Please tell us the facts and circumstances and
your consideration of the guidance in ASC 820 that lead you to concluded that your 50%

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April 8, 2024
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ownership interest had a fair value of $90 million considering Essilor had just acquired the
other 50% for $52.1 million.
Note 6. Income Taxes, page 74
6.Please expand your disclosures to address the following:
•Revise your presentation of the components of your deferred tax assets and liabilities
to disclose the amount by type of asset or liability.  In this regard, we note your
presentation of foreign deferred tax assets and liabilities that does not communicate
to an investor the type of asset or liability.  Refer to ASC 740-10-50-6 for guidance.
•We note that you reduced the valuation allowance by $42 million, which was offset
by an increase of $2.6 million.  However, we did not note a reconciling item for these
changes in the effective tax rate reconciliation.  Please separately present the impact
of changes in the valuation allowance in accordance with ASC 740-10-50-12 and
Article 4-08(h)(2) of Regulation S-X given the significance to your provision for
income tax and net income.
•Disclose here or in the significant accounting policies footnote disclosure your
accounting policy election to provide for the tax on Global Intangible Low Taxed
Income (GILTI) earned by certain foreign subsidiaries.  In addition, disclose the
remaining amount of the one-time transition tax to be remitted.  In your fiscal year
2019 10-K, you stated that you intended to remit payment over an eight-year period.
Form 8-K Filed December 7, 2023
Exhibit 99.1
7.We note that you provide a discussion and analysis for your non-GAAP measures without
providing a discussion and analysis of the comparable US GAAP measure throughout the
earnings release. With reference to Item 10(e)(1)(i)(A) of Regulation S-K and Question
102.10(a) of the Compliance and Disclosure Interpretations for Non-GAAP Financial
Measures, ensure your disclosures, discussion and other presentations do not present,
discuss and/or analyze non-GAAP financial measures with more prominence than the
most directly comparable US GAAP measure.
8.We note your characterization of certain adjustments as unusual, including certain
litigation expense, gain or loss on deconsolidation of subsidiaries, changes in the fair
value of contingent consideration and product transition costs.  Please revise your
description of these types of adjustment to comply with the guidance in Question 102.03
of the Compliance and Disclosure Interpretations for Non-GAAP Financial Measures.
9.Please provide reconciliations for the percentage change in revenue on a constant currency
basis and organic basis, non-GAAP gross margin; non-GAAP operating margin; operating
expense excluding amortization; and net debt as required by Rule 100(a) of Regulation G
and Item 10(e)(1)(i)(B) of Regulation S-K.

 FirstName LastNameBrian G. Andrews
 Comapany NameCOOPER COMPANIES, INC.
 April 8, 2024 Page 4
 FirstName LastName
Brian G. Andrews
COOPER COMPANIES, INC.
April 8, 2024
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10.Please revise your reconciliations to begin with the most comparable US GAAP measure
and to separately present each material adjustment to the US GAAP measure. Provide
footnote disclosures describing what each adjustment represents and to quantify the
components of the adjustment when the adjustment is broad (e.g., restructuring charges or
acquisition-related expenses).  Refer to Item 10(e)(1)(i)(B) of Regulation S-K, Question
102.10(b) of the Compliance and Disclosure Interpretations for Non-GAAP Financial
Measures, and the answer to Question 102.12 of the Compliance and Disclosure
Interpretations for Non-GAAP Financial Measures.
11.Please provide us with the components of Adjustment B for each period presented with
reference to your description of what types of costs are included in acquisition and
integration expenses.  To the extent that a portion of this adjustment relates to personnel
costs for transitional employees and other acquired employee related costs, provide us
with your consideration of the guidance in Question 100.01 of the Compliance and
Disclosure Interpretations for Non-GAAP Financial Measures.
12.Please provide a more comprehensive explanation for the adjustment to provision for
income taxes.  In this regard, we note that you made adjustments to fiscal year 2023 to
arrive at non-GAAP diluted earnings per share totaling $324 million but decreased the
provision for income taxes by $20.1 million without an explanation.  Refer to Question
102.11 of the Compliance and Disclosure Interpretations for Non-GAAP Financial
Measures.
            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 Tracey Houser at 202-551-3736 or Terence O'Brien at 202-551-3355 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services