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Correspondence

 April 24, 2012

VIA EDGAR (“CORRESP”) AND OVERNIGHT MAIL

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549

 Attention:
Mr. Jeffrey Jaramillo

Re:
Masimo Corporation

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

Filed February 17, 2012

Form 8-K Dated February 14, 2012

Filed February 14, 2012

File No. 001-33642

 Dear
Mr. Jaramillo:

 Reference is made to the letter from the staff of the Commission (the
“Staff”), dated April 12, 2012, to Masimo Corporation (the “Company”) with respect to the Company’s Annual Report on Form 10-K for the fiscal year ended
December 31, 2011 and the Company’s Current Report on Form 8-K filed with the Securities and Exchange Commission (the “Commission”) on February 14, 2012 (the “Comment
Letter”). The numbering of the paragraphs below corresponds to the numbering in the Comment Letter, the text of which we have incorporated into this response letter for convenience.

Staff Comments and Company Responses

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

 Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 52

 Critical Accounting Estimates, page 59

 Inventory/Reserves for Excess or Obsolete
Inventory, page 59

 1.    We see disclosures herein that you maintain a general inventory reserve based on your
estimate of future limitations on your ability to utilize the inventory on hand. In light of the referenced disclosures, please tell us how your inventory valuation policies comply with the guidance at SAB Topic 5 (BB).

The Company respectfully advises that Staff that the Company’s “general inventory reserve” is a detailed inventory reserve analysis that
the Company performs each reporting period. The

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Company develops its inventory reserve based on an evaluation of the expected future use of the Company’s inventory on an item by item basis. The Company applies historical obsolescence
rates to estimate the loss on inventory expected to have a recovery value below cost. The Company’s historical obsolescence rates are developed from the Company’s experience for major categories of inventory, which are then applied to
excess inventory on an item-by-item basis. The Company also develops other specific inventory reserves when it becomes aware of other unique events that result in a known recovery value below cost. For inventory items that have been written down,
either due to the inventory reserve analysis or due to a specific event, the reduced value becomes the new cost basis. The new cost basis of an inventory item is not marked up in subsequent periods. The Company believes its valuation policies comply
with the guidance contained in Staff Accounting Bulletin Topic 5 (BB) “Inventory Valuation Allowances.”

 The Company advises the
Staff that in future filings the Company will modify its disclosure of this critical accounting estimate by substituting the Company’s reference to a general inventory reserve with an expanded description of the Company’s estimation
process. The Company expects that its revised description, which will be included in the Company’s quarterly report on Form 10-Q for the quarter ended March 31, 2012, will be substantially as follows:

“Inventories are stated at the lower of cost or market. Cost is determined using a standard cost method, which approximates FIFO
(first-in, first-out). Inventory valuation reserves are recorded for materials that have become obsolete or are no longer used in current production and for inventory that has a market value less than the carrying value in inventory. We generally
purchase raw materials in quantities that we anticipate will be fully used within one year. However, changes in operating strategy and customer demand, and frequent unpredictable fluctuations in market values for such materials can limit our ability
to effectively utilize all of the raw materials purchased and sold through resulting finished goods to customers for a profit. We regularly monitor potential inventory excess, obsolescence and lower market values compared to standard costs and, when
necessary, reduce the carrying amount of our inventory to its market value.

 We develop our inventory reserve based on an
evaluation of the expected future use of our inventory on an item by item basis. We apply historical obsolescence rates to estimate the loss on inventory expected to have a recovery value below cost. Our historical obsolescence rates are developed
from our company specific experience for major categories of inventory, which are then applied to excess inventory on an item by item basis. We also develop other specific inventory reserves when we become aware of other unique events that result in
a known recovery value below cost. For inventory items that have been written down, either due to the inventory reserve analysis or due to a specific event, the reduced value becomes the new cost basis. The new cost basis of an inventory item is not
marked up in subsequent periods. Our inventory reserve was $[amount] and

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$[amount] at [date] and [date], respectively. If our estimates for potential inventory losses prove to be too low, then our future earnings will be affected when the related additional inventory
losses are recorded.”

 Form 8-K Dated and Filed February 14, 2012

 Item 2.02 and Item 9.01

 Exhibit 99.1

2.    We see that in this exhibit you disclose non-GAAP financial measures, including “adjusted net income” and
“adjusted EPS” as well as a percentage increase in rainbow revenues excluding the U.S. military order. However, we do not see where you provided the disclosures required by Item 10(e)(1)(i) of Regulation SK. With a view towards
revised disclosure in future filings, please provide us with a revised Item 2.02 of your Form 8-K and a discussion of your results that complies with Item 10(e)(1)(i) of Regulation S-K. All reconciliations presented should be sufficiently
detailed to allow a reader to understand the nature of the reconciling items. In addition, please confirm that in future periods you will comply with the requirements of Regulation G whenever you publicly disclose material information that includes
a non-GAAP financial measure.

 In response to the Staff’s comment, the Company has presented, as Exhibit A to this letter, how it
would have disclosed Item 2.02 of the Company’s Current Report on Form 8-K filed with the Commission on February 14, 2012 to incorporate the requirements of Item 10(e)(1)(i) of Regulation S-K. The disclosure contained Exhibit A
is marked to show changes against the Company’s previously filed disclosure. The Company believes that the reconciliations presented in Exhibit A are sufficiently detailed to allow a reader to understand the nature of the reconciling items.

 The Company confirms that in future periods the Company will comply with the requirements of Regulation G whenever the Company publicly
discloses material information that includes a non-GAAP financial measure.

 * * * * * * * * * *

The Company acknowledges 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 under the federal securities laws of
the United States.

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 Please advise us if we can provide any
further information or assistance to facilitate your review. Please direct any further comments or questions regarding this response letter to me at (949) 297-7041 or Jeff Hartlin, outside counsel to the Company, at
(650) 320-1804.

 Sincerely,

Masimo Corporation

By:

     /s/ MARK P. DE
RAAD

Name: Mark P. de Raad

Title: Executive Vice President & Chief Financial Officer

 cc:   Jeff Hartlin, Paul Hastings LLP

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 EXHIBIT A

 Item 2.02. Results of Operations and Financial Condition.

 On February 14, 2012, Masimo Corporation (the “Company”) issued a press release announcing its financial results for the fourth quarter and full year ended December 31, 2011. A copy of
the press release is attached hereto as Exhibit 99.1 and is incorporated herein by reference.

 In accordance with General Instruction B.2 of
Form 8-K, the information in this Current Report on Form 8-K, including Exhibit 99.1, shall not be deemed “filed” for purposes of Section 18 of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), or
otherwise subject to the liability of that section, and shall not be incorporated by reference into any registration statement or other document filed under the Securities Act of 1933, as amended (the “Securities Act”), or the Exchange
Act, except as shall be expressly set forth by specific reference in such filing.

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 Exhibit 99.1

 Masimo Reports Fourth Quarter and Full Year 2011 Financial Results;

Provides 2012 Financial Guidance

 Q4 2011 Highlights (compared to Q4 2010):

•

 Total revenue, including royalties, rose 6% to $112.3 million.

•

 Product revenue rose 12% to $104.7 million.

•

 Shipped 34,400 Masimo
SET® and Masimo rainbow® SET units.

•

 Masimo rainbow revenue rose 16% to $9.8 million.

•

 GAAP EPS was $0.23 versus $0.26 in the year-ago period. Excluding one-time items in Q4 2010, GAAP EPS declined 21% in Q4 2011, compared to adjusted EPS
of $0.29 in Q4 2010.

 Full Year 2011 Highlights (compared to 2010):

•

 Total revenue, including royalties, rose 8% to $439.0 million.

•

 Product revenue rose 14% to $406.5 million.

•

 Shipped 148,200 Masimo
SET® and Masimo rainbow® SET units, increasing worldwide installed base by 15%.

•

 Masimo rainbow revenue rose 4% to $34.1 million. Excluding the 2010 U.S. military order, rainbow revenue rose 18%.

•

 GAAP EPS was $1.05 versus $1.21 in 2010, which included a one-time net gain of $0.18. Excluding one-time items in 2010, GAAP EPS rose 2% in 2011 from
$1.03.

 Irvine, California, February 14, 2012 – Masimo (NASDAQ: MASI) today announced its financial results
for the fourth quarter and year ended December 31, 2011.

 Masimo’s total fourth quarter revenue, including royalties, rose 6% to
$112.3 million, compared to $105.6 million for the fourth quarter of 2010. Fourth quarter 2011 product revenue rose 12% to $104.7 million, compared to $93.8 million for the fourth quarter of 2010. For the fourth quarter of 2011, the company’s
worldwide end-user business grew 17% and represented 86% of product revenue. OEM sales, which represented the remaining 14% of product revenue, declined 12% in the fourth quarter of 2011, compared to the same period in 2010. Revenue from Masimo
rainbow product sales rose 16% to $9.8 million in the fourth quarter, compared to $8.4 million for the fourth quarter of 2010.

 Net
income for the fourth quarter was $13.8 million, or $0.23 per diluted share, compared to reported net income of $16.1 million, or $0.26 per diluted share, in the fourth quarter of 2010. Excluding one-time expenses in the year-ago period,
Masimo’s adjusted net income and adjusted earnings per share for the fourth quarter of 2010 were $17.5 million and $0.29, respectively.

For 2011, Masimo’s total revenue rose 8% to $439.0 million, compared to $405.4 million in 2010. The company’s product revenue rose 14% to
$406.5 million, compared to $356.4 million in 2010. Revenue from Masimo rainbow products rose 4% to $34.1 million, compared to $32.9 million in 2010. Excluding the $4.0 million U.S. military order in 2010 that did not repeat in 2011, rainbow revenue
grew by 18%. Royalty revenue declined from $49.0 million in 2010 to $32.5 million in 2011.

 Masimo’s net income for 2011 was $63.7
million, or $1.05 per diluted share, compared to 2010 net income of $73.5 million, or $1.21 per diluted share, which included $0.18 from the net of a one-time gain related to $30.8 million in antitrust proceeds from Covidien and offset by $14.7
million in one-time expenses. Excluding one-time items in 2010, Masimo’s 2010 adjusted net income and adjusted earnings per share were $62.5 million and $1.03, respectively.

 During the fourth quarter, the company shipped approximately 34,400 Masimo SET pulse oximetry and Masimo
rainbow SET Pulse CO-Oximetry units, excluding handheld units, down 18% compared to approximately 41,800 in the same prior-year period. For 2011, Masimo shipped approximately 148,200 Masimo SET pulse oximetry and Masimo rainbow SET Pulse CO-Oximetry
units, excluding handheld units, down 2% compared to approximately 153,200 in 2010. Masimo estimates its worldwide installed base as of December 31, 2011 to be 979,000 units, up 15% from 855,000 units as of January 1, 2011.

Joe Kiani, Chairman and Chief Executive Officer of Masimo, said, “Masimo finished 2011 with a 12% rise in fourth quarter product revenue, including
17% growth in our direct business. Strong double-digit sales growth in our U.S. acute care channel and international business, as well as a 16% increase in rainbow revenue, drove our product revenue performance in the quarter. We also grew our
worldwide installed base by 15%, expanding our global reach and demonstrating the continuing demand for our superior Masimo SET pulse oximetry and rainbow SET Pulse CO-Oximetry technology.”

As of December 31, 2011, cash and cash equivalents were $129.9 million, compared to $88.3 million as of January 1, 2011. During the fourth
quarter, the company used approximately $36 million in cash to purchase approximately 1.8 million shares of its common stock under a stock repurchase program authorized by the Board of Directors in mid-2011.

2012 Financial Guidance

 Masimo expects
fiscal 2012 total revenue to be approximately $483 million, including product revenue of $455 million and royalty revenue of $28 million. Included within the 2012 product revenue guidance is a rainbow revenue expectation of $45 million. The company
expects fiscal 2012 GAAP earnings per share to be $1.20. Each of the components of Masimo’s guidance set forth above is an estimate only and actual performance could differ.

 Conference Call

 Masimo will hold a conference call today at 1:30 p.m. PT (4:30 p.m. ET) to
discuss the results. A live webcast of the conference call will be available online from the investor relations page of the company’s corporate website at www.masimo.com. The dial-in numbers are (888) 520-7182 for domestic callers
and +1 (706) 758-3929 for international callers. The reservation code for both dial-in numbers is 42982286. After the live webcast, the call will be available on Masimo’s website through March 14, 2012. In addition, a telephonic
replay of the call will be available through February 28, 2012. The replay dial-in numbers are (800) 585-8367 for domestic callers and +1 (855) 859-2056 for international callers. Please use reservation code 42982286

About Masimo

 Masimo
(NASDAQ: MASI) is the global leader in innovative noninvasive monitoring technologies that significantly improve patient care—helping solve “unsolvable” problems. In 1995, the company debuted Measure-Through Motion and Low Perfusion
pulse oximetry, known as Masimo SET®, which virtually eliminated false alarms and increased pulse
oximetry’s ability to detect life-threatening events. More than 100 independent and objective studies demonstrate Masimo SET provides the most reliable SpO2 and pulse rate measurements even under the most challenging clinical conditions,
including patient motion and low peripheral perfusion. In 2005, Masimo introduced rainbow® SET Pulse
CO-Oximetry™ technology, allowing noninvasive and continuous monitoring of blood constituents that previously required invasive procedures, including total hemoglobin (SpHb®), oxygen content (SpOC™), carboxyhemoglobin (SpCO®), methemoglobin (SpMet®), and
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