SecProbe.io

May 5 , 2017

Via E -Mail
Mr. Joel Ackerman
Chief Financial Officer
Davita Inc.
2000 16th St.
Denver, CO 80202

Re: Davita Inc.
Form 10 -K for the Fiscal Year Ended December 31 , 2016
Filed February 24, 2017
File No . 001 -14106

Dear Mr. Ackerman :

We have reviewed your filing an d have the following comment .  In our comment , we
may ask you to provide us with information so we may better understand your disclosure.

Please respond to this comment  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comment applies  to your facts and circumstances , please tell us why in your response.

After r eviewing your response to this comment , we may have  additional comments.

Form 10 -K for the Year Ended December 31, 2016

Item 15. Exhibits, Financial Statement Schedules
Note 21. Acquisitions and divestitures, page F -39

1.  We note on Augu st 1, 2016 you consummated an agreement with Khazanah Nasional
Berhad (Khazanah) and Mitsui and Co., Ltd (Mitsui) whereby Khazanah and Mitsui
subscribed to invest a total of $300 million over three years in exchange for a 40% total
equity interest in your Asia Pacific JV. Each of the parties made related initial
investments of $50 million in this business on August 1, 2016. Please provide the
following:

 In the transcript from your earnings call on November 2, 2016, you state “…at
closing, each partner mad e their first investment tranche of $50 million in return for a
6.7% ownership in the joint venture.” Please tell us and revise to disclose the
percentage of ownership interest you held after transferring the 6.7% ownership to
each of the joint venture par tners on August 1, 2016 and clarify why you believe you

Joel Ackerman
Davita Inc.
 May 5 , 2017
Page 2

 were no longer the primary beneficiary and no longer held a controlling financial
interest of the joint venture at August 1, 2016.

 Please clarify your accounting for the remaining $250 million you e xpect to receive
over the three year term and provide any other salient terms to the agreement with
your joint venture partners.

 You indicate that the gain of $374,374 on your retained investment was net of
contingent obligations. Please explain the natu re of the contingent obligations that
were considered in your calculation of this gain and explain how they were valued.

 Please provide your calculation of the gain recorded upon deconsolidation of the joint
venture of $374,374 million, including the inputs and valuation techniques used to
measure the fair value of the retained investment in the joint venture. Please also te ll
us how you considered the $250 million to be received in future periods in the gain
calculation.

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.

You may contact Myra Moosariparambil at (202) 551 -3796 o r Linda Cvrkel at (202) 551 -
3183  with any questions.

Sincerely,

 /s/Craig A rakawa

Craig Arakawa
Accounting Branch Chief
Office of Beverages, Apparel and
Mining