SecProbe.io

August 9, 2024
J. Patrick Mackin
President, Chief Executive Officer and Chairman
Artivion, Inc.
1655 Roberts Boulevard N.W.
Kennesaw, GA 30144
Re:Artivion, Inc.
Definitive Proxy Statement on Schedule 14A
Filed April 1, 2024
File No. 001-13165
Dear J. Patrick Mackin:
            We have limited our review of your most recent definitive proxy statement to those issues
we have addressed in our comment(s).
            Please respond to this letter by providing the requested information and/or confirming that
you will revise your future proxy disclosures in accordance with the topics discussed below. 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.
Definitive Proxy Statement on Schedule 14A
Pay Versus Performance Disclosure, page 68
1.We note that the peer group you identify in footnote (c) to your pay versus performance
table, the S&P Health Care Equipment Index, is different from the peer group used for
your pay versus performance disclosure in the immediately preceding fiscal year's proxy
statement, the NASDAQ Medical Equipment Index. Please tell us the reason(s) for the
change and provide a comparison of your cumulative total return with that of both the
newly selected peer group and the peer group used in the immediately preceding fiscal
year. Also, in future filings when you use a different peer group from the one you used in
the immediately preceding fiscal year, please provide footnote disclosure of the reason(s)
for the change and the total shareholder return comparisons required by Item 402(v)(2)(iv)
of Regulation S-K.
Your disclosure in footnote (d) refers to your Form 8-K filed February 15, 2024, for a
reconciliation of your Company-Selected Measure of revenue growth. Please include in 2.

August 9, 2024
Page 2
the proxy statement disclosure as to how the Company-Selected Measure is calculated
from your audited financial statements, as required by Item 402(v)(2)(vi) of Regulation S-
K. While Company-Selected Measure disclosure is not subject to Regulation G or Item
10(e) of Regulation S-K, you must provide disclosure as to how the Company-Selected
Measure is calculated from your audited financial statements. A reference to non-specific
adjustments determined each year likely does not satisfy this requirement.
            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 Charlotte Young at 202-551-3280 or Amanda Ravitz at 202-551-3412 with
any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program