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 May 5, 2025

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

 Re: Picard Medical, Inc.
 Amendment No. 1 to Registration Statement on Form S-1
 Filed April 25, 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 April 14,
2025 letter.

Amendment No. 1 to Registration Statement on Form S-1 filed April 25, 2025
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Cost of Revenues, page 64

1. We note your response to prior comment 3, whereby you indicate that the
driver is
 rented to the customer when they leave the hospital with the TAH
implant. We also
 note that rental costs are mainly related to machine maintenance.
Finally, we note
 your disclosure on page 69 that the drivers powering the SynCardia TAH
are available
 for in-hospital use (Companion 2) and/or in-hospital and in-home use
(Freedom
 Driver). Please address the following comments:
 Confirm that the patient is the customer for your Freedom Driver
rental
 contracts. Also, confirm that the maintenance expense recognized as
rental costs
 relate solely to your Freedom Drivers. In this regard, we note your
disclosure on
 May 5, 2025
Page 2

 page 16 that you employ and train technicians who can service your
Companion 2
 and Freedom drivers.
 With reference to the contract terms associated with your
Companion 2 drivers,
 please tell us and expand your disclosures, including your
significant revenue
 recognition policies, to identify the customer (i.e. the medical
center or the
 patient), the specific performance obligations under these
contracts, and when you
 recognize revenue associated with Companion 2 drivers. Ensure you
explain your
 maintenance obligations and how the Company allocated the
transaction price to
 each performance obligation consistent with ASC 606-10-32-28 through
32-
 35. To the extent material, quantify the revenues associated with
the Companion 2
 drivers.
 Identify the line item that includes the maintenance expense
associated with your
 Companion 2 drivers.

 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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