SecProbe.io

April 16, 2012
 Via E-Mail

Kent J. Thiry Chief Executive Officer DaVita, Inc. 1551 Wewatta Street Denver, CO 80202
Re: DaVita, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2011
Filed February 24, 2012 File No. 001-14106

Dear Mr. Thiry:
 We have reviewed your filing and have the following comment.  In our comment, we
may ask you to provide us with informati on so we may better understand your disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comment applies to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to this comment, we may have additional comments.

Form 10-K for Fiscal Year Ended December 31, 2011

 Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations

 Critical Accounting Estimates and Judgments, page 63

1. We note you recognized goodwill impairment charges of $24 million relating to your
ancillary business in the second quart er of 2011.  In addition, during your 2011
fourth quarter earnings call you stated that  150 centers are current ly losing money.
Considering the above, with regard to your  impairment testing, please provide us
with, and confirm that in future Exch ange Act filings you will disclose, the
following:
 Clarify what you consider a re porting unit and your basis;
 Of the total number of reporting units  to which goodwill is allocated, how many
were impaired at the date of the most recent test;

Kent J. Thiry DaVita, Inc. April 16, 2012 Page 2

  Clarify how many reporting units, if any, were  considered at risk of impairment
(i.e. in step one of the impairment test, th e reporting unit has a fair value that is
not substantially in excess of its carrying value);
 For any at risk reporting unit, provide us  with (i) the percentage by which fair
value exceeded carrying value as of the date of the most recent test, (ii) the
amount of goodwill allocated to the reporting unit, (iii) a description of the
methods and key assumptions used and how the key assumptions were determined, (iv) a discussion of the degr ee of uncertainty a ssociated with the
key assumptions (i.e. the discussion regarding uncertainty should provide
specifics to the extent possible (e.g., the valuation model assumes recovery from
a business downturn within a defined period of time)), and (v) a description of potential events and/or changes in ci rcumstances that could reasonably be
expected to negatively aff ect the key assumptions.
 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.
 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.

You may contact Blaise Rhode s, Staff Accountant at (202)  551- 3774 or Raj Rajan at
(202) 551-3388 if you have questions regardi ng comments on the financial statements and
related matters.
Sincerely,
   /s/ Brian K. Bhandari for
Tia Jenkins Senior Assistant Chief Accountant Office of Beverages, Apparel and Mining