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SEC Company Response from KESTRA MEDICAL TECHNOLOGIES, (KMTS) — Dec 1, 2025

KESTRA MEDICAL TECHNOLOGIES, LTD.
Date: Dec. 1, 2025 · CIK: 0001877184 · Accession: 0001193125-25-303150

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File numbers found in text: 333-291854

Date
December 1, 2025
Author
Brian Webster
Form
CORRESP
Company
KESTRA MEDICAL TECHNOLOGIES, LTD.

Letter

Re: Kestra Medical Technologies, Ltd. Registration Statement on Form S-1, as amended (File No. 333-291854) Request for Acceleration of Effective Date Ladies and Gentlemen: Kestra Medical Technologies, Ltd. (the “ Registrant ”) hereby requests that the U.S. Securities and Exchange Commission (the “ Commission ”) take appropriate action to cause the above-referenced Registration Statement on Form S-1, as amended, to become effective at 4:00 p.m., Washington, D.C. time, on December 2, 2025, or as soon thereafter as is practicable, or at such later time as the Registrant may orally request via telephone call to the staff of the Commission. The Registrant hereby authorizes each of Sophia Hudson and Christie W.S. Mok of Kirkland & Ellis LLP, counsel to the Registrant, to make such request on its behalf. Once the Registration Statement has been declared effective, please orally confirm that event with Sophia Hudson of Kirkland & Ellis LLP, counsel to the Registrant, at (212) 446-4750, or in her absence, Christie W.S. Mok at (212) 390-4546. [ Signature Page Follows ]

KESTRA MEDICAL TECHNOLOGIES, LTD. 3933 Lake Washington Blvd NE, Suite 200 Kirkland, Washington 98033 December 1, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Industrial Applications and Services 100 F Street, N.E. Washington, D.C. 20549

Attention: Juan Grana Margaret Sawicki Al Pavot Terence O’Brien

Very truly yours,
KESTRA MEDICAL TECHNOLOGIES, LTD.

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CORRESP
 1
 filename1.htm

 CORRESP

 KESTRA MEDICAL TECHNOLOGIES, LTD.
 3933 Lake Washington Blvd NE, Suite 200
 Kirkland, Washington 98033
 December 1, 2025 VIA EDGAR
 U.S. Securities and Exchange Commission Division of Corporation
Finance Office of Industrial Applications and Services 100
F Street, N.E. Washington, D.C. 20549 

 Attention:
 Juan Grana
 Margaret Sawicki Al Pavot
 Terence O’Brien

 Re:
 Kestra Medical Technologies, Ltd.
 Registration Statement on Form S-1, as amended (File No. 333-291854)
 Request for Acceleration of Effective Date
 Ladies and Gentlemen: Kestra Medical
Technologies, Ltd. (the “ Registrant ”) hereby requests that the U.S. Securities and Exchange Commission (the “ Commission ”) take appropriate action to cause the above-referenced Registration Statement on Form S-1, as amended, to become effective at 4:00 p.m., Washington, D.C. time, on December 2, 2025, or as soon thereafter as is practicable, or at such later time as the Registrant may orally request via telephone call
to the staff of the Commission. The Registrant hereby authorizes each of Sophia Hudson and Christie W.S. Mok of Kirkland & Ellis LLP, counsel to the Registrant, to make such request on its behalf.
 Once the Registration Statement has been declared effective, please orally confirm that event with Sophia Hudson of Kirkland & Ellis
LLP, counsel to the Registrant, at (212) 446-4750, or in her absence, Christie W.S. Mok at (212) 390-4546.
 [ Signature Page Follows ]

 Very truly yours,

 KESTRA MEDICAL TECHNOLOGIES, LTD.

 By:

 /s/ Brian Webster

 Name: Brian Webster

 Title: President, Chief Executive Officer and Director

 cc:
 Traci S. Umberger
 Kestra Medical Technologies, Ltd.
 Sophia Hudson, P.C. Christie
W.S. Mok Kirkland & Ellis LLP
 Ilir Mujalovic Allen Overy
Shearman Sterling US LLP [C OMPANY S IGNATURE P AGE TO
A CCELERATION R EQUEST ]