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SEC Company Response from BOSTON SCIENTIFIC CORP (BSX) (CIK 0000885725) (BSX) — Apr 14, 2015

BOSTON SCIENTIFIC CORP (BSX) (CIK 0000885725)
Date: April 14, 2015 · CIK: 0000885725 · Accession: 0000885725-15-000008

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File numbers found in text: 001-11083

Referenced dates: April 9, 2015

Date
April 14, 2015
Author
/s/ Daniel J. Brennan
Form
CORRESP
Company
BOSTON SCIENTIFIC CORP (BSX) (CIK 0000885725)

Letter

United States Securities and Exchange Commission Division of Corporation Finance Comment letter dated April 9, 2015 Form 10-K for the Fiscal Year Ended December 31, 2014 Filed February 25, 2015 File No. 001-11083

Dear Ms. Tillan:

This letter is in response to your letter dated April 9, 2015 regarding the above subject matter. For ease of reference, we have reproduced the Staff’s comment in italicized font below, with our response following the Staff’s comment.

Form 10-K for the Fiscal Year ended December 31, 2014

Item 8. Financial Statements

Consolidated Statements of Comprehensive Income (Loss), page 65

1.

Your consolidated statements of comprehensive income (loss) are on page 65 while your consolidated statements of operations are on page 62. In future filings, to comply with FASB ASC 220-10-45-1 through 45-1B, please either report comprehensive income in a single continuous financial statement or in two separate but consecutive financial statements. Refer to the examples provided at ASC 220-10-55.

We respectfully acknowledge the Staff’s comment and in response, will report comprehensive income in two separate but consecutive financial statements in our Form 10-Q for the period ending March 31, 2015, as well as in future filings.

In connection with our response set forth above, we acknowledge the following:

•We are responsible for the adequacy and accuracy of the disclosure in our filing;

•

Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to our filing; and

•

We may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

We hope that the Staff finds our response to be reasonable and responsive to the Staff’s comment. The Staff should not hesitate to contact me directly at (508) 683-4466 with any questions that it may have.

Very truly yours,
/s/ Daniel J. Brennan

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CORRESP
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		Comment Letter Respons (1)

April 14, 2015

United States Securities and Exchange Commission

Ms. Kate Tillan

Assistant Chief Accountant

Division of Corporation Finance

100 F Street, N.E.

Mail Stop 3030

Washington, D.C. 20549

Re:

 Comment letter dated April 9, 2015

 Form 10-K for the Fiscal Year Ended December 31, 2014

 Filed February 25, 2015

 File No. 001-11083

Dear Ms. Tillan:

This letter is in response to your letter dated April 9, 2015 regarding the above subject matter. For ease of reference, we have reproduced the Staff’s comment in italicized font below, with our response following the Staff’s comment.

Form 10-K for the Fiscal Year ended December 31, 2014

Item 8. Financial Statements

Consolidated Statements of Comprehensive Income (Loss), page 65

1.

 Your consolidated statements of comprehensive income (loss) are on page 65 while your consolidated statements of operations are on page 62. In future filings, to comply with FASB ASC 220-10-45-1 through 45-1B, please either report comprehensive income in a single continuous financial statement or in two separate but consecutive financial statements. Refer to the examples provided at ASC 220-10-55.

We respectfully acknowledge the Staff’s comment and in response, will report comprehensive income in two separate but consecutive financial statements in our Form 10-Q for the period ending March 31, 2015, as well as in future filings.

In connection with our response set forth above, we acknowledge the following:

•We are responsible for the adequacy and accuracy of the disclosure in our filing;

•

 Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to our filing; and

•

 We may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

We hope that the Staff finds our response to be reasonable and responsive to the Staff’s comment. The Staff should not hesitate to contact me directly at (508) 683-4466 with any questions that it may have.

Very truly yours,

 /s/ Daniel J. Brennan

Daniel J. Brennan

Executive Vice President and Chief Financial Officer