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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: 0001193125-25-303153

Offering / Registration Process

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File numbers found in text: 333-291854

Date
December 1, 2025
Author
Milton Hsu
Form
CORRESP
Company
KESTRA MEDICAL TECHNOLOGIES, LTD.

Letter

Re: Kestra Medical Technologies, Ltd. Registration Statement on Form S-1 (File No. 333-291854) Request for Acceleration of Effective Date Ladies and Gentlemen: In connection with the above-referenced Registration Statement, and pursuant to Rule 461 under the Securities Act of 1933, as amended (the “ Act ”), we hereby join in the request of Kestra Medical Technologies, Ltd. (the “ Registrant ”) that the effective date of the Registration Statement be accelerated so that it will be declared effective at 4:00 p.m., Washington, D.C. time, on December 2, 2025, or as soon as thereafter practicable, or at such later time as the Registrant or its outside counsel, Kirkland & Ellis LLP, may orally request via telephone call to the staff of the U.S. Securities and Exchange Commission. Please be advised that we have not distributed any copies of the Preliminary Prospectus dated December 1, 2025 (the “ Preliminary Prospectus ”) through the date hereof, but pursuant to Rule 460 under the Act there will be distributed to underwriters, dealers, institutions and others who are reasonably anticipated to be invited to participate in the distribution of the shares as many copies of the Preliminary Prospectus as appears to be reasonable to secure adequate distribution of the Preliminary Prospectus. Very truly yours, BOFA SECURITIES, INC. PIPER SANDLER & CO. J.P. MORGAN SECURITIES LLC GOLDMAN SACHS & CO. LLC As Representatives of the several underwriters [ Signature Pages Follow ]

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. 20549-6010

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

BOFA SECURITIES, INC.

By:

/s/ Milton Hsu

Name: Milton Hsu

Title: Managing Director

PIPER SANDLER & CO.

By:

/s/ Neil Riley

Name: Neil Riley

Title: Managing Director

J.P. MORGAN SECURITIES LLC

By:

/s/ Benjamin Burdett

Name: Benjamin Burdett

Title: Managing Director, Head of Healthcare Equity Capital Markets

GOLDMAN SACHS & CO. LLC

By:

/s/ Lyla Bibi Maduri

Name: Lyla Bibi Maduri

Title: Managing Director As representatives of the several underwriters cc: Ilir Mujalovic, Allen Overy Shearman Sterling US LLP [ Signature Page to Acceleration Request Letter ]

Show Raw Text
CORRESP
 1
 filename1.htm

 CORRESP

 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. 20549-6010

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

 Re:
 Kestra Medical Technologies, Ltd.
 Registration Statement on Form S-1 (File
 No. 333-291854) Request for Acceleration of Effective Date
 Ladies and Gentlemen: In connection with the above-referenced
Registration Statement, and pursuant to Rule 461 under the Securities Act of 1933, as amended (the “ Act ”), we hereby join in the request of Kestra Medical Technologies, Ltd. (the “ Registrant ”) that the effective
date of the Registration Statement be accelerated so that it will be declared effective at 4:00 p.m., Washington, D.C. time, on December 2, 2025, or as soon as thereafter practicable, or at such later time as the Registrant or its outside
counsel, Kirkland & Ellis LLP, may orally request via telephone call to the staff of the U.S. Securities and Exchange Commission. Please be
advised that we have not distributed any copies of the Preliminary Prospectus dated December 1, 2025 (the “ Preliminary Prospectus ”) through the date hereof, but pursuant to Rule 460 under the Act there will be distributed to
underwriters, dealers, institutions and others who are reasonably anticipated to be invited to participate in the distribution of the shares as many copies of the Preliminary Prospectus as appears to be reasonable to secure adequate distribution of
the Preliminary Prospectus. Very truly yours, BOFA
SECURITIES, INC. PIPER SANDLER & CO. J.P. MORGAN
SECURITIES LLC GOLDMAN SACHS & CO. LLC As
Representatives of the several underwriters [ Signature Pages Follow ]

 BOFA SECURITIES, INC.

 By:

 /s/ Milton Hsu

 Name: Milton Hsu

 Title: Managing Director

 PIPER SANDLER & CO.

 By:

 /s/ Neil Riley

 Name: Neil Riley

 Title: Managing Director

 J.P. MORGAN SECURITIES LLC

 By:

 /s/ Benjamin Burdett

 Name: Benjamin Burdett

 Title: Managing Director, Head of Healthcare Equity Capital Markets

 GOLDMAN SACHS & CO. LLC

 By:

 /s/ Lyla Bibi Maduri

 Name: Lyla Bibi Maduri

 Title: Managing Director
 As representatives of the several underwriters
 cc: Ilir Mujalovic, Allen Overy Shearman Sterling US LLP
 [ Signature Page to Acceleration Request Letter ]