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 May 20, 2025

David R. Bailey
President and Chief Executive Officer
Orthopediatrics Corp
2850 Frontier Drive
Warsaw, Indiana 46582

 Re: Orthopediatrics Corp
 Form 10-K for the Fiscal Year Ended December 31, 2024
 File No. 001-38242
Dear David R. Bailey:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

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

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

Form 10-K for the Fiscal Year Ended December 31, 2024
Critical Accounting Policies and Significant Judgments and Estimates
Inventory Valuation, page 84

1. We note that inventories constitute your largest asset and that the
December 31, 2024
 inventory balance is more than twice the amount of your annual cost of
revenue in
 2024. Please address the following comments related to your inventories
in your
 future filings:
 Disclose the amounts of inventory that you determined to be excess
and obsolete,
 if significant;
 Discuss whether a (presumably) significant amount of consigned
inventory would
 impact your inventory valuation; and if so, consider disclosing the
total amount of
 your consigned inventory held at your sales agencies, distributors
or other
 customers;
 Explain your basis and considerations for classifying all
inventories as current
 assets.
 See Item 303(b)(3) of Regulation S-K.
 May 20, 2025
Page 2

Goodwill and Other Intangible Assets, page 84

2. We note you identified a triggering event related to ApiFix trademark
valuation
 resulting in impairment charges, and also reported reduction of the
ApiFix portfolio
 inventory as part of the restructuring charges. Explain how you have
considered
 ApiFix s lower than expected forecasted revenue and the inventory
write down related
 to restructuring in your goodwill impairment analysis. In that regard,
we note that the
 ApiFix acquisition appeared to have generated significant amount of
goodwill, and
 that you only performed qualitative assessment of your goodwill for your
two
 reporting units in 2024.
3. In future filings, where applicable, please consider providing the
following disclosures
 for each reporting unit that is at risk of failing the quantitative
impairment test as
 defined in ASC 350:
 The percentage by which fair value exceeded carrying value at the
date of the
 most recent test;
 The amount of goodwill allocated to the reporting unit;
 A description of key assumptions used and how they were determined;
 A discussion of the degree of uncertainty associated with key
assumptions and a
 sensitivity analysis of the impact of changes in key assumption; and
 A description of potential events and/or change in circumstances
that could
 reasonably be expected to negatively affect key assumptions.

 In closing, 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.

 Please contact Christie Wong at 202-551-3684 or Li Xiao at 202-551-4391
with any
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Industrial Applications and
 Services
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