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 June 26, 2025

Richard Heppenstall
Executive Vice President, Chief Financial Officer and Treasurer
ZimVie Inc.
4555 Riverside Drive
Palm Beach Gardens, Florida 33410

 Re: ZimVie Inc.
 Form 10-K for Fiscal Year Ended December 31, 2024
 Form 8-K filed February 26, 2025
 File No. 001-41242
Dear Richard Heppenstall:

 We have reviewed your filings 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 Fiscal Year Ended December 31, 2024
15. Segment Data, page 65

1. Please tell us how you have complied with the requirements to disclose
significant
 segment expenses and other segment items required by ASC 280-10-50-26A
and 26B
 or explain how you intend to revise your disclosures to comply with this
guidance. If
 you have no significant expense categories, tell us where and how you
explain the
 nature of the expense information the CODM uses to manage operations as
required
 by ASC 280-10-50- 26C or explain how you intend to revise your
disclosures to
 comply with this guidance.
8-K Filed February 26, 2025
Exhibit 99.1

2. Please expand the footnote disclosures you provide for the adjustments
made to US
 GAAP measures to arrive at non-GAAP measures to discuss all material
components
 and to quantify each component. For example, footnote 1 for the
restructuring and
 other cost reduction initiatives includes employee termination benefits
and
 June 26, 2025
Page 2

 professional fees; and footnote 7 includes the tax effects of the
adjustments and for
 management expectations without additional explanation.
3. We note the other charges adjustment used to calculate multiple non-GAAP
 performance measures for inventory write-offs related to restructurings
and the step-
 up amortization of property, plant and equipment. Please address the
following:
 Quantify the components of the adjustment for each period presented.
 With reference to ASC 420-10-S99-3, tell us your consideration of
the guidance
 in Question 100.01 of the Compliance and Disclosure Interpretations
for Non-
 GAAP Financial Measures for the inventory write-offs portion of the
adjustment.
 Tell us your consideration of the guidance in Question 100.04 of the
Compliance
 and Disclosure Interpretations for Non-GAAP Financial Measures for
the step-up
 amortization of property, plant and equipment portion of the
adjustment reflecting
 part, but not all, of an accounting concept.
4. We note that the acquisition, integration, divestiture and related
adjustment includes
 $2.4 million for professional services fees related to the evaluation of
strategic
 alternatives for your portfolio. Please provide us with an explanation
of the nature of
 these professional fees along with your consideration of the guidance in
Question
 100.01 of the Compliance and Disclosure Interpretations for Non-GAAP
Financial
 Measures.
5. We note your reconciliation for EBITDA and Adjusted EBITDA in which you
include
 an adjustment for depreciation and amortization of $33.2 million
compared to the
 $34.3 million of depreciation and amortization included in the statement
of cash
 flows. Further, we note that footnote 5 for the other charges adjustment
continues to
 reference property, plant and equipment amortization. Please address
this
 inconsistency.
 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 Tayyaba Shafique at 202-551-2110 or Tracey Houser at
202-551-3736
if you have questions regarding comments on the financial statements and
related matters.

 Sincerely,

 Division of
Corporation Finance
 Office of
Industrial Applications and
 Services
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