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April 10, 2024
Raul Parra
Chief Financial Officer and Treasurer
MERIT MEDICAL SYSTEMS INC
1600 West Merit Parkway
South Jordan , Utah 84095
Re:MERIT MEDICAL SYSTEMS INC
Form 10-K for Fiscal Year Ended December 31, 2023
Filed February 28, 2024
Form 8-K Filed February 28, 2024
File No. 000-18592
Dear Raul Parra:
            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 December 31, 2023
Notes to Consolidated Financial Statements, page 59
1.We note from your disclosures in your earnings press releases that you have recognized
corporate transformation and restructuring charges of $19.8 million for fiscal year 2023,
$23.8 million for fiscal year 2022, and $18.7 million for fiscal year 2021, representing
16%, 27% and 31% of operating income, respectively. Please tell us why you have not
provided an accounting policy for recognizing restructuring charges and the disclosures
required by ASC 420-10-50-1 and SAB Topic 5:P in your footnote and MD&A
disclosures.
10. Commitments and Contingencies
Litigation, page 78
2.We note your disclosure that the various claims and litigation matters you are involved in
could have a material adverse effect on your financial position, results of operations and

 FirstName LastNameRaul Parra
 Comapany NameMERIT MEDICAL SYSTEMS INC
 April 10, 2024 Page 2
 FirstName LastName
Raul Parra
MERIT MEDICAL SYSTEMS INC
April 10, 2024
Page 2
cash flows.  Please provide specific disclosures for these matters.  Otherwise, if true then
clearly state that other than as disclosed for the SEC inquiry your claims and litigation
matters are not expected to materially impact your financial position, results of operations,
or cash flows individually or in the aggregate.  Disclosures for the amount or range of
reasonably possible loss in the aggregate, or that you are unable to reasonably estimate the
amount or range, should also be provided, noting that ASC 450-20-50-4 does not require
the amount or range of reasonably possible loss to be estimated with precision or
certainty.
Form 8-K Filed February 28, 2024
Exhibit 99.1
3.We note your adjustments for corporate transformation and restructuring for your non-
GAAP performance measures. Please provide us with an explanation of what specifically
each of these adjustments represent and quantify the components for each period
presented. Confirm to us that you will provide a more detailed discussion of these
adjustments along with quantifying the components for each period presented.
            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 Al Pavot at 202-551-3738 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services