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 April 14, 2025

Patrick NJ Schnegelsberg
Chief Executive Officer
Picard Medical, Inc.
1992 E Silverlake
Tucson AZ, 85713

 Re: Picard Medical, Inc.
 Registration Statement on Form S-1
 Filed April 1, 2025
 File No. 333-286295
Dear Patrick NJ Schnegelsberg:

 We have reviewed your amended registration statement and have the
following
comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. 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 any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our February 7,
2025 letter.

Registration Statement on Form S-1 filed April 1, 2025
Risk Factors
Our stockholders may be subject to significant dilution..., page 48

1. We note your disclosure here that certain of your preferred shares and
related party
 loans will convert into shares of your common stock upon consummation of
this IPO.
 We also note your revised disclosure on page 105 describing the
conversion terms of
 your notes and loans. To provide investors with additional context
related to potential
 dilution, please provide an estimate of the number of shares of common
stock into
 which your preferred shares and related party loans will convert.
 April 14, 2025
Page 2
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Revenues, page 62

2. You indicate that the decrease in revenues is related to the loss of a
distributor in
 fiscal 2023. Please revise to quantify the lost revenues related to that
particular
 distributor. In addition, please revise to further clarify what is meant
by "the lost
 momentum in establishment of in-house sales personnel" and discuss any
related
 trends.
Cost of Revenues, page 63

3. It appears that you have materially revised the cost of revenues for
products and rental
 income for the year ended December 31, 2023. Please address the
following:
 Tell us the reasons underlying this change.
 Based on your disclosures elsewhere in the filing, we note that the
SynCardia
 TAH consists of the SynCardia TAH implant, an external pneumatic
driver and
 drivelines. Please clarify whether the drivers are sold as part of
the system sold. If
 so, clarify the nature of your maintenance obligations and confirm
that your costs
 of products sold include such costs.
4. Your discussion regarding the cost of revenues appears to discuss the
components of
 costs of revenues but does not explain the decrease in costs in fiscal
2024. Please
 explain what you mean by "...a $1.5 million in overhead variance for the
drivers, $1.0
 million overhead variance for the TAH, and $0.6 material usage variance
for the
 TAH." Ensure your discussion addresses why your cost of products as a
percentage of
 sales significantly decreased from 2023 to 2024.
5. Please reconcile your disclosure here which indicates that rental
revenue is earned
 when a patient is discharged from a hospital with a Freedom Driver and
that rental
 revenue is "recognized when it becomes likely that we will receive
payment," with
 your financial statement disclosure which indicates that "rental revenue
is generally
 recognized over time on a ratable basis over the period of usage
beginning on the date
 that the service is made available. Rental revenue is billed at month
end and typically
 collected within 30 days."
Business
Overview
Our Business, page 69

6. We note your revised disclosure in response to prior comment 1. However,
the
 disclosure regarding outcomes from the use of LVADs and other temporary
MCS
 compared to the outcomes obtained with the SynCardia TAH is still
included on page
 69 of the prospectus. To the extent that this disclosure is not based on
head-to-head
 clinical trial data, please remove it throughout your filing.
Certain Relationships and Related Transactions, page 104

7. You refer to "Collateral" in your revised disclosure throughout this
section. Given that
 this appears to be a defined term, please revise your disclosure to
briefly describe the
 relevant collateral.
 April 14, 2025
Page 3

Financial Statements
Summary of Significant Accounting Policies - Segment Information, page F-15

8. Please expand your disclosures to provide all the disclosures required
by ASC 280-10-
 50. Ensure you address (i) your segment measure of profit or loss, (ii)
the segment
 significant expense categories and amounts that regularly provided to
the CODM and
 included in the reported segment profit or loss, (iii) other segment
items with a
 qualitative description of the composition of other segment items and
(iv) segment
 assets. See ASC 280-10-50-22, 50-25, 50-26 and 50-26A-C. See also ASC
280-10-55-
 15D through 15-F.
 Please contact Julie Sherman at 202-551-3640 or Jeanne Baker at
202-551-3691 if
you have questions regarding comments on the financial statements and related
matters. Please contact Conlon Danberg at 202-551-4466 or Katherine Bagley at
202-551-
2545 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
cc: Michael J. Blankenship, Esq.
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