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March 6, 2024
Gary M. Owens
Chief Executive Officer
Mesa Laboratories, Inc.
12100 West Sixth Avenue
Lakewood, Colorado 80228
Re:Mesa Laboratories, Inc.
Form 10-K for the Fiscal Year Ended March 31, 2023
Filed May 30, 2023
File No. 000-11740
Dear Gary M. Owens:
            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
 comments apply 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 March 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Critical Accounting Policies and Estimates, Acquired Intangible Assets, page 33
1.Reference your disclosure on page that you performed impairment tests of goodwill as a
result of loss of a significant customer and financial performance.   We also reference
disclosure that Clinical Genomics’ intangible assets and goodwill "may be impaired in the
near term." In future filings, revise to provide information for investors to assess the
probability of future goodwill impairment charges. For example, for each reporting
unit at risk of failing an impairment test, disclose the following:

•the percentage by which fair value exceeded carrying value at the date of the most
recent test;
•a detailed description of the methods and key assumptions used and how the key
assumptions were determined
•a discussion of the degree of uncertainty associated with the assumptions; and

 FirstName LastNameGary M. Owens
 Comapany NameMesa Laboratories, Inc.
 March 6, 2024 Page 2
 FirstName LastNameGary M. Owens
Mesa Laboratories, Inc.
March 6, 2024
Page 2
•a description of potential events and/or changes in circumstances that could
reasonably be expected to negatively affect the key assumptions. Refer to Item
303(b)(3) of Regulation S-K.
Form 10-Q for the Quarterly Period Ended December 31, 2023
Condensed Consolidated Financial Statements
Note 2. Significant Transactions, Acquisition of GKE, page 7
2.We note that effective on October 16, 2023, you acquired 100 % of the outstanding shares
of GKE GmbH and SAL GmbH.  Please tell us how you considered the impact of this
acquisition in considering whether you are required to provide financial statements of the
acquiree and pro forma financial information under Rule 3-05 and Article 11 of S-X. Your
response should include your assessment of each significance test in accordance with Rule
1-02(w) of Regulation S-X in assessing compliance with Rule 3-05(a)(2)(ii) of Regulation
S-X.
Form 8-K dated February 5, 2024
Exhibit 99.1
3.Revise future filings to reconcile adjusted operating income excluding unusual items to
the most comparable GAAP measure, Operating (loss) income on a GAAP basis.
Reference Item 10(e)(i) of Regulation S-K and Question 102.10(b) of the C&DI on Non-
GAAP Financial Measures.  As a related matter, please revise future filings to
appropriately label operating income excluding unusual items and adjusted operating
income excluding unusual items as "Non-GAAP."
4.Please provide us with the composition of the non-GAAP adjustment "GKE
acquisition/integration costs" and explain to us how those adjustments meet the
requirements of Question 100.01 of the C&DI on Non-GAAP Financial Measures. Future
filings should also include a detailed disclosure of the nature of each non-GAAP
adjustment.

 FirstName LastNameGary M. Owens
 Comapany NameMesa Laboratories, Inc.
 March 6, 2024 Page 3
 FirstName LastName
Gary M. Owens
Mesa Laboratories, Inc.
March 6, 2024
Page 3
            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 Christie Wong at 202-551-3684 or Kristin Lochhead at 202-551-3664 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services