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 July 3, 2025

Robert Ball
Chief Executive Officer
Shoulder Innovations, Inc.
1535 Steele Avenue SW, Suite B
Grand Rapids, MI 49507

 Re: Shoulder Innovations, Inc.
 Amendment No. 2 to Draft Registration Statement on Form S-1
 Submitted June 18, 2025
 CIK No. 0001699350
Dear Robert Ball:

 We have reviewed your amended draft registration statement and have the
following
comments.

 Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our June 9, 2025 letter.

Amendment No. 2 to Draft Registration Statement on Form S-1
Reverse Stock Split, page 13

1. As a reminder, please note the guidance in SAB 4:C and SAB 4:D regarding
your
 impending stock split.
 July 3, 2025
Page 2
Critical Accounting Policies and Estimates, page 98

2. We have read your response to prior comment 4. Given the materiality of
your
 inventory balance, please expand your disclosure to quantify the extent
to which the
 asset account includes products for which there were no material sales
during the most
 recent period. Reconcile this data with your conclusion that your March
31, 2025
 inventory reserve is adequate. Your existing disclosure acknowledges the
existence of
 aged inventory but does not provide any context enabling a reader to
gauge their
 significance relative to the corresponding reserves. The risk factor on
page 20 appears
 relevant in this regard. See Item 303(b)(3) of Regulation S-K.
Statements of Operations, page F-4

3. We have read your response to prior comment 7. We understand from your
disclosure
 on page F-24 that you have chosen to exclude depreciation and
amortization expense
 from your cost of goods sold account balances on pages F-4 and F-16.
Consequently,
 it appears that the guidance in SAB 11:B is applicable. It is not clear
whether the
 absence of parenthetical disclosures, or the existing presentation of
gross profit,
 are appropriate. Further, it appears that your discussion of COGS in
MD&A should
 include a prominent clarification that your reported cost of goods sold
balances do not
 include depreciation and amortization expense. The guidance in Item
10(e)(1) of
 Regulation S-K may also be applicable. Please revise accordingly or
explain.

 Please contact Al Pavot at 202-551-3738 or Li Xiao at 202-551-4391 if
you have
questions regarding comments on the financial statements and related matters.
Please contact
Juan Grana at 202-551-6034 or Jane Park at 202-551-7439 with any other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Industrial Applications and
 Services
cc: Ross McAloon, Esq.
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