SecProbe.io

September 24, 2012

Via Email
Kent J. Thiry
Chief Executive Officer
DaV ita Inc.
1551 Wewatta Street
Denver, CO 80202

Re: DaV ita Inc.
  Amended Registration Statement on Form S-4
Filed  September 18 , 2012
  File No.  333-182572

Dear Mr. Thiry :

We have limited our review of your registration statement to those issues we have
addressed in our 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 by amending your registration statement and providing the
requested information .  Where you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments , we may have  additional comments.

Form S -4

The Merger, page 80

1. We note your disclosure on page 94 that Davita believes that numerous material
assumptions made in HCP’s September 2011 forecast “would differ” due to the passage
of time.  Please advise us of the meaning of this statement.  In this respect, to the extent
that Davita believes certain material assumptions are no longer reasonable as of the date
of the prospectus, your disclosure should be revised to address.  In addition, please
remove or substantially revise the statement that “none of DaVita or HCP or any of their
respective affiliates, advisors or representatives assumes any responsibility for the
accuracy of the forecasts, or has made or makes any representation to any person that
they considered, or now consider, the forecasts to be a reliable prediction  of actual future
events or results, and the forecasts should not be relied upon as such.”  The company is

Kent J. Thiry
DaVita Inc.
September 24, 2012
Page 2

 responsible for the disclosure in the prospectus and investors should be able to rely upon
such information.

We urge all persons who are responsible  for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   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.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the  proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

Please contact Jay Williamson at (202) 551 -3393  or Pam Howell at (202) 551 -3357  with
any questions.

Sincerely,

 /s/ Pamela Howell
 for

John Reynolds
Assistant Director

Cc:  David Slotkin