SecProbe.io

May 2 1, 2015

Via E -mail
Mr. Joe Kiani
Chief Executive Officer
Masimo  Corporation
52 Discovery
Irvine, CA  92618

Re: Masimo Corporation
 Form 10-K for the Fiscal Year Ended January 3, 2015
Filed February 17, 2015
Form 8 -K dated May 6, 2015
Filed May 6, 2015
File No. 001-33642

Dear Mr. Kiani :

We have reviewed your filing an d 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 these comments  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
comments apply to your facts and ci rcumstances , please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Form 10 -K Fiscal Year Ended January 3, 2015

Note 2. Summary of Significant Accounting Policies, page F -8

1. We note your disclosure relating to  litigation costs and c ontingencies  in Note  15 and in
MD&A on page 71. Please revise future filings to include your  accounting policy for loss
contingencies in the notes to the audited financial statements.  Refer to FASB  ASC 235 -
10-50-1.

Note 15.  Commitments and Contingencies , page F -28

2. We note that in discussing many of the litigation matters on pages F -30 through F -32 you
disclose  that you “believe [you] have good and substantial defenses…but there is no

Mr. Mr. Kiani
Masimo Corporation
May 2 1, 2015
Page 2

 guarantee that [you] will prevail.”  In future filings, in addition to disclosing the nature of
the contingency, please revise the note to provide all the disclosures required by ASC
450-20-50.  As applicable, disclose the estimate of possible loss, or ran ge of loss or
include a statement that such an estimate cannot be made.  Further, i f there is at least a
reasonable possibility that a loss exceeding amounts already recognized may be incurred,
revise to either disclose an estimate of the additional loss o r range of loss, or state that
such an estimate  cannot be made.

Note 16.   Segment Information and Enterprise Reporting, page F -32

3. We note y our disclosure in this note that your assets are primarily located in the U nited
States  but also note the discuss ion of properties in Item 2 on page 49.   Please revise
future filings to provide the disclosures required by FASB ASC 280 -10-50-41(b).  In this
regard, you should separately quantify the long -lived assets in your country of domicile
(United States) and all foreign countries.  See also ASC 280 -10-55-23.

Form 8 -K dated  May 6, 2015

Exhibit 99.1

4. We note your reconciliation of GAAP to non -GAAP Condensed Consolidated Statements
of Income.  Please tell us how you  considered the guidance set forth in Question 102.10
of our Compliance and Di sclosure Interpretation s on Non-GAAP Financial Measures ,
which indicates that it is generally not appropriate to present a non -GAAP income
statem ent for purposes of reconciling non -GAAP financial measures to the most directly
comparable GAAP financial measures.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing inc ludes the information the Securities Exchange Act of
1934 and all applicable Exchange 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 adeq uacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure 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 u nder the federal securities laws of the United States.

Mr. Mr. Kiani
Masimo Corporation
May 2 1, 2015
Page 3

 You may contact Tara Harkins at (202) 551 -3639 or Eric Atallah , Senior  Accountant,  at
(202) 551 -3663 if you have questions regarding comments on the financial statements and
related matters . You may al so contact me at (202) 551 -3671.

       Sincerely,

       /s/ Martin James

        Martin James
        Senior Assistant Chief Accountant