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
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File numbers found in text: 333-291854
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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 ]