SecProbe.io

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 April 23, 2026

Phillip B. Berry
Chief Financial Officer
Enovis Corporation
2711 Centerville Road, Suite 400
Wilmington, Delaware 19808

 Re: Enovis Corporation
 Form 10-K for the Fiscal Year Ended December 31, 2024
 File No. 001-34045
Dear Phillip B. Berry:

 We have completed our review of your filings. We remind you that the
company and its
management are responsible for the accuracy and adequacy of their disclosures,
notwithstanding
any review, comments, action or absence of action by the staff.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and Services
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CORRESP
 1
 filename1.htm

 2711
Centerville Road

 Suite
400

 Wilmington,
Delaware 19808

 United
States

 enovis.com

 April
8, 2026

 VIA
EDGAR

 Ms.
Kristin Lochhead and Ms. Li Xiao

 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

 Re:
 Enovis
 Corporation

 Form
 10-K for the Fiscal Year Ended December 31, 2024

 Form
10-Q for the Fiscal Quarter Ended October 3, 2025 File No. 001-34045

 Dear
Ms. Lochhead and Ms. Xiao:

 We
are writing in response to the comments received by Enovis Corporation (the “ Company ”) from the staff of the
Securities and Exchange Commission’s Division of Corporation Finance (the “ Staff ”) by letter dated February
20, 2026. For the Staff’s convenience, we have set forth below each of the numbered comments in the Staff’s letter in bold,
followed by the Company’s response thereto.

 Form
10-Q for the Fiscal Quarter Ended October 3, 2025

 Item
2. Management’s Discussion and Analysis of Financial Condition and Results of Operations

 Non-GAAP
Measures, page 31

 1. We
 have reviewed your response to comment 2 and we believe that the non-GAAP adjustment for
 the purchase of royalty interest is inconsistent with Question 100.01 of the Compliance &
 Disclosure Interpretations on Non-GAAP Financial Measures. Please remove this non-GAAP adjustment
 from your presentation of Adjusted EBITDA and Adjusted Net Income in future filings, including
 the presentation in the press release on Form 8-K.

 Response:
 We respectfully acknowledge the Staff’s comment and advise the Staff that the Company
 continues to believe that its non-GAAP adjustment for the purchase of royalty interest is
 appropriate for the reasons set forth below, as well as those set forth in our prior responses
 to the Staff.

 April 8, 2026

 Page 2

 The
 adjustment reflects the one-time, non-recurring, up-front expense recognized by the Company
 to acquire third-party royalty interests, which represents the purchase of a long-term economic
 right rather than a cost incurred in the ordinary course of producing or delivering the Company’s
 products or services. As described in the Company’s prior responses, the expense was
 incurred as part of a one-time, strategic decision to terminate existing product development
 agreements and acquire the associated royalty interests in connection with the transformation
 of the Company’s product development model and is fundamentally different from operating
 expenses incurred to run the Company’s business on a recurring basis. The Company does
 not anticipate entering into similar transactions on a recurring basis in connection with
 any future changes or additions to its core product development teams.

 The
 royalty buyouts were a foundational element of the Company’s transition to the new
 model, as they facilitated a shift in the way design surgeons are compensated for their development
 of the Company’s global product portfolio. The Company believes that this new model,
 which primarily aligns compensation with growth in the Company’s overall Reconstructive
 portfolio rather than individual products, will accelerate its pace of innovation by, among
 other things (i) incorporating new and diverse viewpoints to ensure that global and regional
 differences and preferences are considered in the product development process (which is of
 critical importance to the Company, given its expanded global reach following its acquisitions
 of Mathys and Lima), (ii) ensuring that the Company receives candid and unbiased guidance
 in integrating and rationalizing acquired product portfolios, (iii) placing additional emphasis
 on rapidly developing and expanding enabling technologies, and (iv) fostering an environment
 that encourages product development partners to provide strategic advice on research and
 development activities that cut across individual projects and product lines.

 As
 noted above, a key benefit of the new model is the emphasis it places on candid and unbiased
 advice in the product development process. Under the Company’s legacy project-focused
 approach to innovation, product development partners were incentivized to devote their time
 and attention to projects to which they are assigned and to products for which they receive
 royalties. Consequently, these prominent partners with considerable clinical and design expertise
 may not be fully incentivized to provide broader ideas or innovative insights beyond the
 scope of their discrete engagements and may be less likely to provide high value innovative
 ideas to the Company in a project-focused setting because there are no incentives to do so.
 Specifically, under the legacy model, if an idea for a next generation product could disrupt
 the existing portfolio or sunset certain products for which a product development partner
 currently receives royalties, they may be disincentivized from pursuing such an idea.

 By
 terminating and buying out the royalty interests under the legacy agreements with its leading
 product development partners, the Company was able to significantly accelerate the shift
 to the new model by eliminating these disincentives, while also ensuring that it fulfilled
 its pre-existing contractual obligations under the legacy agreements through the negotiated
 settlements. The amounts to be paid each year under the buyout agreements are fixed and are
 not dependent on future operational factors. The buyout amounts were determined on an individual
 basis as a result of arm’s-length negotiations with the counterparties.

 April 8, 2026

 Page 3

 Additionally,
 the Company respectfully submits that the purchase of the royalty interest is not the
 type of “normal, recurring, cash operating expense” contemplated by Question
 100.01 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures (each
 question thereof, a “C&DI”) because it is not a period operating cost
 incurred to generate current-period revenues, but rather a discrete transaction that
 restructures the economics of a pre-existing royalty arrangement by converting a contingent,
 sales-based obligation into a fixed purchase price. Stated differently, while ongoing
 royalties (if payable) may be recurring operating costs, the buyout of the royalty
 interest is a one-time strategic transaction to eliminate future contingent
 royalties and replace them with a single negotiated consideration amount and therefore is
 not indicative of the Company’s normal operating cost structure.

 Further,
 to the extent the Staff’s “recurrence” concern is based on the fact that
 the acquired or underlying intellectual property may continue to be incorporated into the
 Company’s products or that the purchase consideration may be settled over multiple
 periods, the Company respectfully submits that neither point changes the nature of the item
 being adjusted. The relevant question under Question 100.01 of the C&DI is whether the
 adjustment removes a normal, recurring operating expense, and the Staff has emphasized
 that the analysis turns on the nature and effect of the adjustment in the context
 of the business—not the timing of cash settlement. Here, the purchase reflects a discrete,
 negotiated restructuring of an economic right; once executed, the Company’s future
 recurring royalty expense under the terminated agreements is eliminated, rather than being
 “normalized” out of operating results.

 The
 adjustment isolates a transaction that is fundamentally different from recurring operating
 costs incurred to operate the business. The Company respectfully submits that, under the
 Staff’s own framework in Question 100.01 of the C&DI—which evaluates the
 nature, effect, and context of an adjustment—the exclusion of the purchase of royalty
 interest from Adjusted EBITDA and Adjusted Net Income does not obscure the Company’s
 operating performance and therefore does not render the measure misleading.

 Moreover,
 the Company has clearly described the nature of the purchase of the royalty interest and
 the rationale for the adjustment, reconciled Adjusted EBITDA and Adjusted Net Income to the
 most directly comparable GAAP measures, and presented the GAAP measures with equal or greater
 prominence. The adjustment is applied consistently and is not selectively applied to exclude
 only unfavorable items.

 As
 stated in our Non-GAAP Measures disclosure in our periodic reports, Adjusted EBITDA is intended
 to facilitate period-over-period comparability by excluding items that “occur with
 inconsistent frequency,” “obscure underlying business trends,” or relate
 to “discrete restructuring plans and other initiatives that are fundamentally different
 from our ongoing productivity improvements.” We believe the adjustment provides investors
 with a clear and meaningful view of our underlying business trends, aligns with how management
 evaluates the business and enhances comparability across periods.

 April 8, 2026

 Page 4

 For
 these reasons, as well as the reasons set forth in the Company’s prior responses to
 the Staff’s comments, the Company believes that excluding the purchase of the royalty
 interest from Adjusted EBITDA and Adjusted Net Income provides investors with a more meaningful
 depiction of the Company’s underlying operating performance and is consistent with
 Regulation G and the guidance in Question 100.01 of the C&DI.

 In
 future filings, the Company will supplement its disclosure regarding the adjustment to provide
 additional detail and context for why the Company believes such adjustment is useful to investors
 as follows:

 “Purchase
of royalty interest represents the one-time, up-front expense incurred by the Company to acquire the economic rights to future royalties
under product development agreements in connection with the termination of such agreements as part of a strategic shift to a new product
development model. The Company believes that excluding the impact of such expense enhances comparability between periods, provides investors
with a clear and meaningful view of our underlying business trends and aligns with how management evaluates the ongoing business performance.”

 2. We
 have reviewed your response to comment 3 and we believe that the non-GAAP adjustment for
 Inventory step-up in connection with acquired businesses is inconsistent with Question 100.04
 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. Please remove
 this non-GAAP adjustment from your presentation of Adjusted EBITDA and Adjusted Net Income
 in future filings, including the presentation in the press release on Form 8-K.

 Response :
 We respectfully acknowledge the Staff’s comment.  The Company continues to believe
 that its non-GAAP adjustment for Inventory step-up in connection with acquired businesses
 (i) is appropriate and consistent with Question 100.04 of the C&DI and the requirements
 of Rule 100(b) of Regulation G, (ii) enhances comparability between periods by removing the
 one-time, transaction-related Inventory step-up expense arising from the application of purchase
 accounting under GAAP that is not a reflection of our current or ongoing cost to manufacture
 product, and (iii) provides investors with a better understanding of the Company’s
 business performance and underlying gross margin trends. The adjustment is intended to eliminate
 the impact of a one-time, transaction-related step-up to reflect cost of goods sold as if
 such acquired inventory had been produced by the Company and sold in the ordinary course
 of business, absent which we believe the Company’s gross margins would have been
 viewed by investors as artificially low and distorted during the period when step-up charges
 were recognized in cost of goods sold.  We believe that such an adjustment is particularly
 useful to investors in the context of a significant acquisition of a company that is engaged
 in the inventory and capital-intensive large joint implant business, such as Lima, which
 had approximately 16 months of inventory on hand as of the date of acquisition. We believe
 that this adjustment significantly enhanced comparability between periods, allowing investors
 to better understand our business performance and the underlying trends relevant to our ongoing
 business performance. This is further evidenced by the fact that following the completion
 of amortization of the Inventory step-up from its recently acquired businesses, the Company’s
 GAAP gross margin remains on trend with our previously reported adjusted gross margins.

 However,
 we understand and respect the Staff’s position and will remove this non-GAAP adjustment
 from our presentation of Adjusted EBITDA and Adjusted Net Income in future filings, including
 the presentation in press releases on Form 8-K.

 April 8, 2026

 Page 5

 3. We
 note your response to prior comment 4. To the extent that the non-GAAP adjustments for strategic
 transaction costs continue to be material to the non-GAAP measures, in future filings please
 include more detailed quantitative and qualitative information about the nature of the adjustments,
 similar to the response.

 Response:
 We respectfully acknowledge the Staff’s comment. We have included more detailed quantitative
 and qualitative information about the nature of such adjustments in our Form 10-K for the
 year ended December 31, 2025, and will continue to provide such information in future filings
 to the extent that non-GAAP adjustments for strategic transaction costs continue to be material
 to our non-GAAP measures.

 Form
10-K for the Fiscal Year Ended December 31, 2025

 Consolidated
Financial Statements

 Note
19. Segment Information, page 106

 4. We
 note your response to comment 1 and reissue in part. Please disclose how the CODM uses the
 reported measure of segment profit or loss in assessing segment performance and deciding
 how to allocate resources in future filings. Refer to ASC 280-10-50-29(f) and the example
 in ASC 280-10-55-47(bb).

 Response:
 We respectfully acknowledge the Staff’s comment. We have revised our disclosure in
 our Form 10-K for the year ended December 31, 2025 in response to the Staff’s comment,
 and will continue to provide such disclosure in future filings.

 ****

 Should
you have any further questions on the above, please do not hesitate to contact me at (469) 227-0054.

 Sincerely,

 /s/ Phillip B. Berry

 Phillip B. Berry

 Senior Vice President and Chief
Financial Officer

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<TEXT>
 February 20, 2026

Phillip B. Berry
Chief Financial Officer
Enovis Corporation
2711 Centerville Road, Suite 400
Wilmington, Delaware 19808

 Re: Enovis Corporation
 Form 10-K for the Fiscal Year Ended December 31, 2024
 Form 10-Q for the Fiscal Quarter Ended October 3, 2025
 File No. 001-34045
Dear Phillip B. Berry:

 We have reviewed you January 30, 2026 response to our comment letter and
have the
following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments. Unless
we note otherwise, any references to prior comments are to comments in our
December 22, 2025
letter.

Form 10-Q for the Fiscal Quarter Ended October 3, 2025
Item 2. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Non-GAAP Measures, page 31

1. We have reviewed your response to comment 2 and we believe that the
non-GAAP
 adjustment for the purchase of royalty interest is inconsistent with
Question 100.01 of the
 Compliance & Disclosure Interpretations on Non-GAAP Financial Measures.
 Please remove this non-GAAP adjustment from your presentation of
Adjusted EBITDA
 and Adjusted Net Income in future filings, including the presentation
in the press release
 on Form 8-K.
 February 20, 2026
Page 2
2. We have reviewed your response to comment 3 and we believe that the
non-GAAP
 adjustment for Inventory step-up in connection with acquired businesses
is inconsistent
 with Question 100.04 of the Compliance and Disclosure Interpretations on
Non-GAAP
 Financial Measures. Please remove this non-GAAP adjustment from your
presentation
 of Adjusted EBITDA and Adjusted Net Income in future filings, including
the
 presentation in the press release on Form 8-K.
3. We note your response to prior comment 4. To the extent that the
non-GAAP
 adjustments for strategic transaction costs continue to be material to
the non-GAAP
 measures, in future filings please include more detailed quantitative
and qualitative
 information about the nature of the adjustments, similar to your
response.
Form 10-K for the Fiscal Year Ended December 31, 2025
Consolidated Financial Statements
Note 19. Segment Information, page 106

4. We note your response to comment 1 and reissue in part. Please disclose
how the CODM
 uses the reported measure of segment profit or loss in assessing segment
performance
 and deciding how to allocate resources in future filings. Refer to ASC
280-10-50-29(f)
 and the example in ASC 280-10-55-47(bb).

 Please contact Kristin Lochhead at 202-551-3664 or Li Xiao at
202-551-4391 if you have
questions regarding comments on the financial statements and related matters.

 Sincerely,

 Division of
Corporation Finance
 Office of
Industrial Applications and
 Services
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 2711
Centerville Road

 Suite
400

 Wilmington,
Delaware 19808

 United
States

 enovis.com

 January
30, 2026

 VIA
EDGAR

 Ms.
Kristin Lochhead and Ms. Li Xiao

 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

 Re:
 Enovis
 Corporation

 Form
 10-K for the Fiscal Year Ended December 31, 2024

 Form
 10-Q for the Fiscal Quarter Ended October 3, 2025 File No. 001-34045

 Dear
Ms. Lochhead and Ms. Xiao:

 We
are writing in response to the comments received by Enovis Corporation (the " Company ") from the staff of the
Securities and Exchange Commission's Division of Corporate Finance (the " Staff ") by letter dated December
22, 2025. For the Staff's convenience, we have set forth below each of the numbered comments in the Staff's letter in bold,
followed by the Company's response thereto.

 Form
10-K for the Fiscal Year Ended December 31, 2024

 Consolidated
Financial Statements

 Note
19. Segment Information, page 106

 1.
 You
 disclose the chief operating decision maker (CODM) evaluates the operating results of each of your reportable segments based upon
 Net sales and Adjusted EBITDA. We also note that your Management's Discussion and Analysis includes disclosure of gross profit
 and operating loss (GAAP) by reportable segment. Please tell us whether gross profit and operating loss (GAAP) by reportable segment
 are reported to the CODM and the extent to which each measure is used to evaluate segment performance and allocate resources. If
 either of these measures are considered by the CODM when assessing performance and allocating resources, please explain how you determined
 the appropriate measure to report under ASC 280-10-50-28A. Finally, revise to disclose how the CODM uses the reported measure of
 segment profit or loss in assessing segment performance and deciding how to allocate resources. Refer to ASC 280-10-50-29(f) and
 the example in ASC 280-10-55-47(bb).

 Response :
 We respectfully acknowledge the Staff's comment and advise the Staff that the gross profit and operating loss (GAAP) by reportable
 segment are not reported to the CODM and are not used to evaluate segment performance and allocate resources. The measures that are
 included in the Company's reporting package that is provided to the CODM and used by the CODM to evaluate segment performance
 and allocate resources are Net sales and Adjusted EBITDA.

 January
30, 2026

 Page
2

 Form
10-Q for the Fiscal Quarter Ended October 3, 2025

 Item
2. Management's Discussion and Analysis of Financial Condition and Results of Operations

 Non-GAAP
Measures, page 31

 2.
 We
 reference your response to prior comment 1. It appears that the non-GAAP adjustment for the purchase of royalty interest is related
 to a normal recurring operating expense for which a non-GAAP adjustment would be inconsistent with Question 100.01 of the Compliance
 & Disclosure Interpretations (C&DI) for Non-GAAP Financial Measures. In that regard, we note that the underlying intellectual
 property developed in connection with the related agreements continues to be incorporated into the company's products. Therefore,
 it appears that those costs relate to the generation of revenue and would be considered normal operating expenses. Please revise
 your presentation to remove the adjustment for purchase of royalty interest from your Adjusted EBITDA measures in future filings
 as well as the presentation of Adjusted Net Income included in the press release on Form 8-K. Alternatively, tell us why you continue
 to believe that the adjustment is consistent with the C&DI.

 Response :
 We respectfully acknowledge the Staff's comment and, in particular, the notion that a portion of the purchase of royalty interest
 relates to the generation of future revenues. We believe that the adjustment for the purchase of royalty interest is appropriate
 because the expense reflects a discrete, upfront strategic transaction that fundamentally restructures the economic terms of pre-existing
 royalty arrangements, is not expected to recur, and is not part of our normal operating cost structure.

 With
 respect to the fact that the purchase price for the royalty interests will be paid over a multi-year period, we respectfully submit
 that the timing of cash settlement should not be determinative of whether an item constitutes a normal, recurring operating expense.
 Pursuant to Question 100.01 of the C&DI for Non-GAAP Financial Measures, "[w]hen evaluating what is a normal, operating
 expense, the staff considers the nature and effect of the non-GAAP adjustment and how it relates to the company's operations,
 revenue generating activities, business strategy, industry and regulatory environment." (emphasis added) Accordingly, our view
 is that the economic substance of the transaction, rather than the form or duration of payment, is the relevant consideration. In
 this case, the obligation to make payments over a seven-year period reflects the commercial terms under which the parties agreed
 to finance a single, discrete economic transaction, and does not convert the underlying cost into an operating expense that recurs
 as part of our ordinary-course revenue-generating activities. We believe that the nature of the adjustment remains that of a non-recurring,
 strategic, transaction-related expense that was incurred in order to restructure the Company's long-term royalty profile, which
 is not incurred repeatedly and which does not arise each period in connection with the Company's operations or revenue generating
 activities, such as manufacturing, distribution, or sales activities.

 January
 30, 2026

 Page
3

 We
 acknowledge the intellectual property remains part of our products and is relevant to revenue generation. However, the charges associated
 with the purchase of royalty interests had no material connection to revenue recorded in the periods affected, resulting in notable
 one-time impacts on our financial trends. We are not aware of any requirement in the SEC's rules or guidance to consider such
 charges "normal operating expenses" simply because they relate to future revenue. Additionally, we did not view these
 one-time charges as "necessary to run the business" because we entered into these strategic transactions voluntarily.

 We
 believe that the adjustment made by the Company fits within the Staff's interpretative framework, and that a cost does not
 become "recurring" merely because the cash outflows occur over multiple periods. The Company believes that the most relevant
 inquiry remains whether the cost is part of the issuer's ongoing cost structure, and here it is not. The multi-year payment
 schedule is simply a financing mechanism for a one-time restructuring of an economic right, not evidence of ongoing operating activity.

 As
 included in our Non-GAAP Measures disclosure in our periodic reports, Adjusted EBITDA is intended to facilitate period-over-period
 comparability by excluding items that "occur with inconsistent frequency," "obscure underlying business trends,"
 or relate to "discrete restructuring plans and other initiatives that are fundamentally different from our ongoing productivity
 improvements." The purchase of royalty interest represents a one-time upfront economic investment made to restructure the economics
 of pre-existing royalty arrangements. Although the underlying intellectual property acquired in connection with the royalty interest
 continues to be incorporated into our products, the nature of the transaction-related expense is not indicative of the Company's
 normal cost structure and does not recur in the ordinary course of business. We believe that the effect of the adjustment is that
 it provides investors with a clear and meaningful view of our underlying business trends, aligns with how management evaluates the
 business and enhances comparability across periods.

 Accordingly,
 we continue to believe the adjustment is appropriate and consistent with Question 100.01 of the C&DI for Non-GAAP Financial Measures
 and the Staff's other guidance on the topic. However, we will supplement our disclosures in future filings to further clarify
 the nature of the royalty interest purchase and why management views this item as non-recurring and not reflective of ongoing operating
 expenses. Further, as noted in our prior response, the purchase of royalty interests that occurred in 2025 was an isolated, non-recurring
 event to facilitate the transition to the Company's new product development model, and the Company does not currently contemplate
 any further similar buyout transactions in the future.

 January
 30, 2026

 Page
4

 3.
 Reference
 the non-GAAP adjustment related to Inventory step-up. Please tell us why you believe an adjustment for inventory step-up charges
 in connection with acquired businesses does not change the recognition and measurement principles required to be applied in accordance
 with GAAP. Refer to Question 100.04 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. Alternatively,
 please revise your presentation to remove this non-GAAP adjustment to Adjusted net income and Adjusted EBITDA measures in future
 filings, including the presentation in the press release on Form 8-K.

 Response :
 We respectfully acknowledge the Staff's comment and have reviewed the guidance provided in Question 100.04 of the C&DI
 for Non-GAAP Financial Measures. We advise the Staff that the acquired inventory step-up adjustments are intended to eliminate the
 impact of applying fair value principles in our purchase accounting, in accordance with ASC 805 Business Combinations, for
 inventory sold during the relevant periods and is not an individually tailored expense recognition methodology.

 Inventory
 step-up charges represent the incremental expense of inventory sold recognized at its fair value after business combination accounting
 is applied versus the expense that would have been recognized if sold at its cost to manufacture. Since (i) only the inventory that
 existed at the business combination date was stepped-up to fair value and (ii) the Company's costs to continue to manufacture
 such inventory following the dates of such acquisitions remained the same as those for the acquired companies, we believe excluding
 the incremental expense provides investors useful information as to what our costs may have been if we had not been required to increase
 the inventory's carrying value to fair value. The adjustment is intended to eliminate the impact of a one-time, transaction-related
 step-up to reflect cost of goods sold as if such acquired inventory had been produced by the Company and sold in the ordinary course
 of business. We believe that this adjustment enhances comparability between periods, allowing investors to better understand our
 business performance and the underlying trends relevant to our ongoing business performance.

 In
 future filings, the Company will supplement its disclosure regarding any such Inventory step-up charges to provide additional context
 for why the Company believes that such adjustments are useful to investors as follows:

 "Inventory
 step-up expense represents the incremental expense of inventory sold recognized at its fair value after business combination accounting
 is applied versus the expense that would have been recognized if sold at its cost to manufacture. Since only the inventory that existed
 at the business combination date was stepped-up to fair value, we believe excluding the incremental expense (i) provides investors
 useful information as to what our costs may have been if we had not been required to increase the inventory's book value to
 fair value and (ii) enhances comparability between periods, allowing investors to better understand our business performance and
 the underlying trends relevant to our ongoing business performance."

 January
 30, 2026

 Page
5

 4.
 We
 note that you continue to include material non-GAAP adjustments for strategic transaction costs. Please tell us why you continue
 to adjust your non-GAAP measures for these costs and explain why they are not normal, recurring cash operating costs. With your response,
 please include information about the expenses/(benefits) incurred through September 30, 2025. In addition, describe in more detail
 the nature of the payroll costs and retention expenses for which non-GAAP adjustments were made in 2024 and 2025. Please reference
 Question 100.01 of the C&DI for Non-GAAP Financial Measures.

 Response :
 We respectfully acknowledge the Staff's comment. We have reviewed Question 100.01 of the C&DI for Non-GAAP Financial Measures
 and the Staff's other guidance on the topic we believe that the adjustment for strategic transaction costs is appropriate.
 The Company has completed a large number of acquisitions and other transformational transactions, including the spin-off of our former
 fabrication technology business, over the past three years, and the complexity of these transactions and the one-time costs required
 to successfully integrate acquisitions have varied meaningfully based on the nature of each acquisition. The most significant of
 these transactions have been the spin-off of our ESAB business that was completed in April 2022 and our acquisition of Lima completed
 in January 2024. We have continued to exclude strategic transaction costs in our non-GAAP measures in order to provide investors
 with a supplemental view of financial performance of the Company, as we believe that these costs are not indicative of the ongoing
 operations of the Company. In addition, as our integration activities for these transactions near completion, we expect that the
 related adjustments for strategic transaction costs will continue to decline.

 The
 table set forth below provides additional details of the expenses/(benefits) incurred through the end of the third quarter of 2025,
 which ended on October 3, 2025, including the nature of the payroll costs and retention expenses for which non-GAAP adjustments were
 made during the year ended December 31, 2024 and during the nine months ended October 3, 2025.

 Lima
 related acquisition and integration costs:
 Nine
 Months Ended
 October
 3, 2025
 Year
 Ended
 Dec
 31, 2024

 Payroll
 costs and retention expenses (1)
 $ 6.9
 $ 13.1

 Integration
 and migration of IT systems
 2.8
 12.5

 Deal
 costs (2)
 0.0
 15.4

 Rebranding
 costs (3)
 0.6
 5.9

 Operational
 integration costs (4)
 14.4
 17.9

 Other
 strategic transaction costs:

 Other
 (non-Lima) acquisition integration costs (5)
 5.1
 6.9

 Separation
 related costs (6)
 1.2
 4.6

 Other
 charges (7)
 10.2
 2.0

 Total
 Strategic transaction costs
 $ 41.2
 $ 78.3

 (1)
 Includes
 payroll and retention costs for (a) roles eliminated in connection with the integration of our recent acquisition of Lima where a
 legal notice period was required prior to the employee's separation from the Company, or (b) integration-related daily activities
 not related to former roles performed by an employee during their legal notice period and prior to their separation from the Company.
 In each case, such costs relate solely to roles eliminated in connection with the integration of the Lima acquisition, and are non-recurring
 and not part of our normal business operations.

 January
 30, 2026

 Page
6

 (2)
 Includes
 professional and consulting fees specifically incurred to consummate the acquisition and advise and facilitate on post-acquisition
 integration matters including legal entity consolidation.

 (3)
 Includes
 non-recurring integration related costs associated with rebranding and marketing acquired businesses under Enovis name, such trade
 show redesign costs and product re-labeling.

 (4)
 Includes
 non-recurring integration related costs associat

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 December 22, 2025

Phillip B. Berry
Chief Financial Officer
Enovis Corporation
2711 Centerville Road, Suite 400
Wilmington, Delaware 19808

 Re: Enovis Corporation
 Form 10-K for the Fiscal Year Ended December 31, 2024
 Form 10-Q for the Fiscal Quarter Ended October 3, 2025
 File No. 001-34045
Dear Phillip B. Berry:

 We have reviewed your August 5, 2025 response to our comment letter and
have the
following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our July 22,
2025 letter.

Form 10-K for the Fiscal Year Ended December 31, 2024
Consolidated Financial Statements
Note 19. Segment Information, page 106

1. You disclose the chief operating decision maker (CODM) evaluates the
operating
 results of each of your reportable segments based upon Net sales and
Adjusted
 EBITDA. We also note that your Management s Discussion and Analysis
includes
 disclosure of gross profit and operating loss (GAAP) by reportable
segment. Please
 tell us whether gross profit and operating loss (GAAP) by reportable
segment are
 reported to the CODM and the extent to which each measure is used to
evaluate
 segment performance and allocate resources. If either of these measures
are
 considered by the CODM when assessing performance and allocating
resources,
 please explain how you determined the appropriate measure to report
under ASC 280-
 10-50-28A. Finally, revise to disclose how the CODM uses the reported
measure of
 December 22, 2025
Page 2

 segment profit or loss in assessing segment performance and deciding how
to allocate
 resources. Refer to ASC 280-10-50-29(f) and the example in ASC
280-10-55-47(bb).
Form 10-Q for the Fiscal Quarter Ended October 3, 2025
Item 2. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Non-GAAP Measures, page 31

2. We reference your response to prior comment 1. It appears that the
non-GAAP
 adjustment for the purchase of royalty interest is related to a normal
recurring
 operating expense for which a non-GAAP adjustment would be inconsistent
with
 Question 100.01 of the Compliance & Disclosure Interpretations (C&DI)
for Non-
 GAAP Financial Measures. In that regard, we note that the underlying
intellectual
 property developed in connection with the related agreements continues
to be
 incorporated into the company's products. Therefore, it appears that
those costs relate
 to the generation of revenue and would be considered normal operating
expenses.
 Please revise your presentation to remove the adjustment for purchase of
royalty
 interest from your Adjusted EBITDA measures in future filings as well as
the
 presentation of Adjusted Net Income included in the press release on
Form 8-
 K. Alternatively, tell us why you continue to believe that the
adjustment is consistent
 with the C&DI.
3. Reference the non-GAAP adjustment related to Inventory step-up. Please
tell us why
 you believe an adjustment for inventory step-up charges in connection
with acquired
 businesses does not change the recognition and measurement principles
required to be
 applied in accordance with GAAP. Refer to Question 100.04 of the
Compliance and
 Disclosure Interpretations on Non-GAAP Financial Measures.
Alternatively, please
 revise your presentation to remove this non-GAAP adjustment to Adjusted
net
 income and Adjusted EBITDA measures in future filings, including the
presentation
 in the press release on Form 8-K.
4. We note that you continue to include material non-GAAP adjustments for
strategic
 transaction costs. Please tell us why you continue to adjust your
non-GAAP measures
 for these costs and explain why they are not normal, recurring cash
operating costs.
 With your response, please include information abut the
expenses/(benefits) incurred
 through September 30, 2025. In addition, describe in more detail the
nature of
 the payroll costs and retention expenses for which non-GAAP adjustments
were made
 in 2024 and 2025. Please reference Question 100.01 of the C&DI for
Non-GAAP
 Financial Measures.
 December 22, 2025
Page 3

 Please contact Kristin Lochhead at 202-551-3664 or Li Xiao at
202-551-4391 if you
have questions regarding comments on the financial statements and related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
</TEXT>
</DOCUMENT>

United States securities and exchange commission logo
December 8, 2022
Christopher Hix
Chief Financial Officer
Enovis Corporation
2711 Centerville Road, Suite 400
Wilmington, Delaware 19808
Re:Enovis Corporation
Form 10-K for the Fiscal Year Ended December 31, 2021
Filed February 22, 2022
File No. 001-34045
Dear Christopher Hix:
            We have completed our review of your filing.  We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services

CORRESP
1
filename1.htm

Document

2711 Centerville Road
Suite 400
Wilmington, Delaware  19808

United States

enovis.com

December 6, 2022

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: Ms. Kristin Lochhead and Brian Cascio

    Re:    Enovis Corporation

        Form 10-K for the Fiscal Year Ended December 31, 2021

        Filed February 22, 2022

        Form 10-Q for the Quarterly Period Ended September 30, 2022

        Filed November 2, 2022

        File No. 001-34045

Dear Ms. Lochhead and Mr. Cascio:

We are writing in response to the comment we received from the staff of the Securities and Exchange Commission (the “Staff”) by letter dated November 22, 2022 regarding the above-referenced filings of Enovis Corporation (the “Company” or “we”). For ease of reference, we have also reproduced below the text of the Staff's comment in italics directly above the Company’s response.

Form 10-Q for the Quarterly Period Ended September 30, 2022

Condensed Consolidated Financial Statements for the Nine Months Ended September 30, 2022

Note 14. Segment Information, page 23

1.We note that you reconcile segment Adjusted EBITDA to operating loss. Please explain to us how this reconciliation is consistent with the guidance in ASC 280-10-50-30(b) that requires a reconciliation of the reportable segments' measures of profit or loss to consolidated income before income taxes and discontinued operations. In addition, tell us how you considered Question 103.02 of the Compliance & Disclosure Interpretations for Non-GAAP Financial Measures dated April 4, 2018 in your reconciliation to Adjusted EBITDA (non-GAAP) in MD&A on pages 31 and 32.

Response:

We acknowledge and appreciate the Staff’s comments.  Regarding our segment footnote presentation and reconciliation pursuant to ASC 280-10-50-30(b), in future filings we will revise the tabular reconciliation included in the “Segment Information” footnote to our financial statements to reconcile the total of our reportable segments’ measure of profit and loss (segment Adjusted EBITDA) to consolidated Income (loss) from continuing operations before income taxes.

In response to the Staff’s comment regarding our reconciliation to Adjusted EBITDA (non-GAAP) in the MD&A on pages 31 and 32 of our Form 10-Q for the quarterly period ended September 30, 2022, in future filings we will revise our presentations by no longer including a table reconciling consolidated Operating loss (GAAP) to Adjusted EBITDA (non-GAAP), and related margin percentages, such as the table that appeared on page 31 of the Form 10-Q for the quarterly period ended September 30, 2022.  In addition, in future filings we will revise the tables which currently reconcile operating income (loss) to Adjusted EBITDA by segment and at the consolidated level, such as the tables that appeared on page 32 of the Form 10-Q for the quarterly period ended September 30, 2022, to instead reconcile from Net income (loss) from continuing operations to Adjusted EBITDA at the consolidated level and for each of our reportable segments. In the context of these tables, we will also present corresponding GAAP and non-GAAP margins.

*    *    *

Should you have any further questions on the above, please do not hesitate to contact me at (302) 252-9160.

Sincerely,

/s/ Christopher M. Hix

Christopher M. Hix

Executive Vice President and Chief Financial Officer

cc:    John Kleckner, Vice President, Chief Accounting Officer

    Bradley Tandy, Senior Vice President and General Counsel

    Brian Hanigan, Vice President, Chief Counsel – Securities, Governance, M&A and Corporate Secretary

    Ronald O. Mueller, Gibson, Dunn & Crutcher LLP

United States securities and exchange commission logo
November 22, 2022
Christopher Hix
Chief Financial Officer
Enovis Corporation
2711 Centerville Road, Suite 400
Wilmington, Delaware 19808
Re:Enovis Corporation
Form 10-K for the Fiscal Year Ended December 31, 2021
Filed February 22, 2022
Form 10-Q for the Quarterly Period Ended September 30, 2022
Filed November 2, 2022
File No. 001-34045
Dear Christopher Hix:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.  In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
            Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 10-Q for the Quarterly Period Ended September 30, 2022
Condensed Consolidated Financial Statements for the Nine Months Ended September 30, 2022
Note 14. Segment Information, page 23
1.We note that you reconcile segment Adjusted EBITDA to operating loss. Please explain to
us how this reconciliation is consistent with the guidance in ASC 280-10-50-30(b) that
requires a reconciliation of the reportable segments' measures of profit or loss to
consolidated income before income taxes and discontinued operations.  In addition, tell us
how you considered Question 103.02 of the Compliance & Disclosure Interpretations for
Non-GAAP Financial Measures dated April 4, 2018 in your reconciliation to Adjusted
EBITDA (non-GAAP) in MD&A on pages 31 and 32.

 FirstName LastNameChristopher Hix
 Comapany NameEnovis Corporation
 November 22, 2022 Page 2
 FirstName LastName
Christopher Hix
Enovis Corporation
November 22, 2022
Page 2
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Kristin Lochhead at (202) 551-3664 or Brian Cascio, Accounting
Branch Chief, at (202) 551-3676 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services