SecProbe.io

January 29, 2025
Brian Webster
Chief Executive Officer
Kestra Medical Technologies, Ltd.
3933 Lake Washington Blvd NE, Suite 200
Kirkland, WA 98033
Re:Kestra Medical Technologies, Ltd.
Amendment No. 3 to Draft Registration Statement on Form S-1
Submitted January 17, 2025
CIK 0001877184
Dear Brian Webster:
            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 January 7, 2025 letter.
Amendment No. 3 to Draft Registration Statement on Form S-1
Prospectus Summary
Our Market Opportunity, page 4
We note your response to comment 1, including your disclosure on page 5 that
"indications for use of WCDs include patients with a LVEF less than or equal to 35%
and a MI within the past 40 days, patients who have had a revascularization procedure
within the past three months, or patients with nonischemic cardiomyopathy with heart
failure symptoms and potentially reversible causes; patients with documented VT/VF
or an inherited genetic condition that places them at high risk for SCA; or patients
who have had their ICD temporarily explanted." Given it appears that patients who do 1.

January 29, 2025
Page 2
not have a low LVEF are eligible for WCD therapy, please revise to explain why you
base your U.S. and international total market opportunity on patients with low LVEF
rather than all patients eligible for WCD therapy, or advise. Please also revise your
disclosures on page iii to briefly explain how you selected the various select
international markets.
Use of Proceeds, page 92
2.We note your response to comment 3. Please revise to more specifically identify
the approximate amount of your net proceeds to be used for each of the principal
purposes disclosed. Refer to Item 504 of Regulation S-K.
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Gross Margin, page 103
3.It appears that your explanation for the October 31 gross profit variance is
substantially identical to your explanation for the April 30 variance. However, it is not
clear why you were able to generate a 36% gross profit margin on the $27 million of
sales generated in the October 31, 2024 period whereas the margin on your $27
million of sales in the April 30, 2024 period was only 1%. Please expand your
disclosure to identify the primary causes for this disparity i.e. changes in pricing,
impairment charges, uncollectible accounts, etc.
Critical Accounting Policies, page 113
4.We have read your response to prior comment 6 and reissue in part. Please expand
your disclosure to clearly explains the material risks that impact the valuation of this
asset. In this regard, your risk factor on page 32 addresses potential losses from
damage and return failures but does not state whether such losses have historically
been material. Such disclosure is necessary for readers to fully assess the magnitude
of this risk.
Business
Our Clinical Results and Studies, page 136
5.We note your response to comment 9. Please revise to briefly discuss how you
collected the real-world evidence in connection with the ACE-PAS study.
Unaudited Condensed Consolidated Financial Statements of West Affum Intermediate
Holdings Corp.
Note 10, page F-20
6.It appears that the disclosures here and on page F-42 should state the the stock was
issued to the Parent. The existing disclosure states that the Company issued stock "of
the Parent".
Note 11, page F-20
7.Please clarify this disclosure to explain why the stock is characterized as "Redeemable
Ordinary Shares" given your stated conclusion that the stock "is not considered
redeemable". Please also tell us how you considered ASC 480-10-S99-3A regarding
the classification of the stock.

January 29, 2025
Page 3
            Please contact Al Pavot at 202-551-3738 or Terence O'Brien at 202-551-3355 if you
have questions regarding comments on the financial statements and related matters. Please
contact Juan Grana at 202-551-6034 or Margaret Sawicki at 202-551-7153 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:Sophia Hudson, P.C.