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 March 27, 2025

Shubham Maheshwari
Chief Financial Officer
Varex Imaging Corporation
1678 S. Pioneer Road
Salt Lake City, Utah 84104

 Re: Varex Imaging Corporation
 Form 10-K for the Fiscal Year Ended September 27, 2024
 Filed November 19, 2024
 Form 8-K Furnished November 19, 2024
 File No. 001-37860
Dear Shubham Maheshwari:

 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 8-K Furnished November 19, 2024
Exhibit 99.1

1. We note your non-GAAP measures include an adjustment for "other
non-operational
 costs." Please tell us the amount and nature of each material component
of this
 adjustment in fiscal year 2024 and how you determined that they were not
normal
 and recurring operating expenses necessary to operate your business.
Specifically
 address the propriety of adjusting for inventory write-downs of
discontinued
 products. See Question 100.01 of the Compliance and Disclosure
Interpretations
 on Non-GAAP Financial Measures. Please present a separate line item for
any
 individual amounts that are material in future filings.
Form 10-K for the Fiscal Year Ended September 27, 2024
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
 March 27, 2025
Page 2

Comparison of Results of Operations for Fiscal Years 2024 and 2023, page 31

2. Where you describe two or more business reasons that contributed to a
material
 change in a financial statement line item between periods, please
quantify, where
 possible, the extent to which each factor contributed to the overall
change in that line
 item, including any offsetting factors. In addition, where you identify
intermediate
 causes of changes in your operating results, also describe the reasons
underlying the
 intermediate causes. We note your disclosures that the changes in
segment revenues,
 revenues by region, and segment gross profit from fiscal year 2023 to
fiscal year 2024
 were due to lower sales in your China business and changes in sales of
various
 products. To the extent possible, quantify the impact of each
contributing factor in
 dollars and/or percentage, expand on the reasons driving these changes,
and provide
 greater transparency into the material components and potential
variability of your
 revenues and gross profit.
Liquidity and Capital Resources
Cash Flows, page 34

3. Please provide a more informative analysis and discussion of changes in
operating,
 investing and financing cash flows for each period presented. In doing
so, explain the
 underlying reasons and implications of material changes between periods
to provide
 investors with an understanding of trends and variability in cash flows.
Also provide
 an analysis of any known trends and uncertainties that will result in or
that are
 reasonably likely to result in a material increase or decrease in your
liquidity. Ensure
 your discussion and analysis is not merely a recitation of changes
evident from the
 financial statements. Refer to Item 303(a) of Regulation S-K and Section
IV.B of SEC
 Release No. 33-8350.
Critical Accounting Estimates
Goodwill and Intangible Assets, page 36

4. We note that you conducted a quantitative goodwill impairment test
during the fourth
 quarter of fiscal 2024 due to indicators of possible impairment. Please
disclose
 whether any of your reporting units are at risk of failing the goodwill
impairment
 test. A reporting unit is at risk of failing the impairment test if it
has a fair value that is
 not substantially in excess of carrying value. If no reporting units are
at risk based on
 your most recent impairment test, disclose such information to your
readers as we
 believe it provides them with valuable information in assessing the
sensitivity of your
 goodwill to future impairment. Alternatively, if a reporting unit is at
risk of failing the
 impairment test and a material impairment charge could occur, please
disclose the
 following:
 The percentage by which fair value exceeded carrying value as of the
date of the
 most recent test;
 The amount of goodwill allocated to the reporting unit;
 A description of the methods and key assumptions used and how the
key
 assumptions were determined;
 A discussion of the degree of uncertainty associated with the key
 March 27, 2025
Page 3

 assumptions. The discussion regarding uncertainty should provide
specifics to the
 extent possible (e.g., the valuation model assumes recovery from a
business
 downturn within a defined period of time); and
 A description of potential events and/or changes in circumstances
that could
 reasonably be expected to negatively affect the key assumptions.
17. Segment Information, page F-38

5. Although we note you disclose revenues by segment and geography on page
F-39,
 please tell us how you considered further disaggregation of your
revenues pursuant to
 ASC 606-10-50-5 and ASC 606-10-55-89 through 55-91, such as by modality,
 vertical, sales channel, customer type, and timing of revenue
recognition. We note that
 you provide pie charts reflecting segment revenue by modality and
vertical in your
 earnings presentation for the first quarter of fiscal year 2025. See
also the guidance in
 ASC 280-10-50-40.
6. We note your page 31 disclosure regarding the impact of your China
business on the
 decrease in Medical segment revenues. We further note you discuss your
sales in
 China during the earnings call for the first quarter of fiscal year
2025. Pursuant to
 ASC 280-10-50-41, please revise future filings to disclose revenues from
external
 customers attributed to each individual foreign country, if material.
7. We note your disclosure on page 13 that one customer accounted for 18%
of your
 fiscal year 2024 revenue. Please revise future filings to disclose the
identity of the
 segment(s) reporting the revenues from such customer pursuant to ASC
280-10-50-
 42.
 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 Stephany Yang at 202-551-3167 or Andrew Blume at
202-551-3254
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
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