SecProbe.io

March 25, 2 011
 Via E-mail

Kent J. Thiry, Chief Executive Officer DaVita Inc. 1551 Wewatta Street Denver, Colorado  80202       RE:   DaVita Inc.
              Form 10-K for Fiscal Year Ended December 31, 2010
              Filed February 25, 2011               File No. 1-14106

Dear Mr. Thiry:
We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within te n business days by providing the requested
information, or by advising us when you will provide the requested response.  If you do not believe our comments apply to your facts and circum stances, please tell us w hy in your response.
 After reviewing the information you provide in response to these comments, we may
have additional comments.
Exhibit Index

1. In future filings, please revi se your reference to Exhibit 10.1, Employment Agreement,
and Exhibit 10.14, Amendment to Equity Award  Agreement to incorporate by reference
these exhibits, as they were not filed with the Form 10-K.

2. We note that Exhibit 10.62 is missing exhibits  and/or schedules.  Please confirm you will
file this exhibit in its entirety  with your next periodic repo rt.  This would include filing
the Perfection Certificate as de livered at closing, rather than  the form of the certificate.
 Closing Comments

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Kent J. Thiry
DaVita Inc. March 25, 2011 Page 2

 In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

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

• the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

Please contact Janice McGuirk, examiner at (202) 551-3395 or Pam Howell,
legal reviewer at (202) 551-3357 with any questions.

Sincerely,
   /s/ Pamela Howell  for   John Reynolds,
Assistant Director