July 16, 2024

Brian G. Andrews
Executive Vice President, Chief Financial Officer and Treasurer
COOPER COMPANIES, INC.
6101 Bollinger Canyon Road, Suite 500
San Ramon, California 94583

       Re: COOPER COMPANIES, INC.
           Form 10-K for Fiscal Year Ended October 31, 2023
           Form 8-K Filed May 30, 2024
           Response Letter Dated July 8, 2024
           File No. 001-08597
Dear Brian G. Andrews:

       We have reviewed your July 8, 2024 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 June 6,
2024 letter.

Form 10-K for Fiscal Year Ended October 31, 2023
Consolidated Statements of Income

1.     We note your response to comment 1. Given that you initially stated in
your response
       letter dated May 22, 2024 related to comment 3 that you would revise the
cost of sales
       line item to include the parenthetical to note that it excludes
amortization of intangibles
       and remove the gross profit subtotal and now have concluded that the
missing
       amortization of intangibles is immaterial and will no longer comply with
the requirements
       in Item 10(e)(1)(ii)(C) of Regulation S-K and SAB Topic 11:B, please
provide us with
       your full materiality analysis in accordance with SAB Topic 1:M that
includes how you
       calculated the amount of excluded intangible asset amortization given
that a portion of the
       composite intangible asset includes a technology component.
 July 16, 2024
Page 2


Note 1. Organization and Significant Accounting Policies
Revenue Recognition

2.     We note your response to comment 2. Considering the significance of
total consolidated
       revenue to the Consolidated Statements of Income and the other financial
statements
       provided, please provide us with a comprehensive materiality analysis
prepared in
       accordance with SAB Topic 1:M to clearly demonstrate that your service
revenues are
       immaterial to your consolidated financial statements, including the
amount of revenues
       and associated costs and income being recognized for each period
presented including
       your subsequent interim periods. Also, provide us with your accounting
policy for your
       revenues. To the extent that you conclude the service revenues are
material to your
       consolidated financial statements, we continue to request that you
provide the disclosures
       for revenues related to the various services you provide including (a)
identification of the
       performance obligations (i.e., when typically satisfied, significant
payment terms, nature
       of goods and services, obligations for returns, refunds, and other
similar obligations, and
       types of warranties and related obligations) with reference to ASC
606-10-50-12 and 50-
       12A, (b) significant judgments for the method used to recognize revenue
over time and
       why the method faithfully depicts the transfer of the services with
reference to ASC 606-
       10-50-18, and (c) variable consideration and any other obligations with
reference to ASC
       606-10-50- 20.

Form 8-K Filed May 30, 2024
Exhibit 99.1

3.     We note your response to comment 7 that the $106.5 million and $42.3
million intra-
       entity asset transfers adjustment to arrive at non-GAAP Net Income is to
realize the
       income tax benefit based on the amortization of these assets. Please
provide us with a
       more comprehensive understanding of what the nature of this adjustment
is, what you are
       trying to convey with it, and how the amount is determined for each
period presented. As
       part of your response, tell us your consideration of the guidance in
Question 100.04 of the
       Non-GAAP Financial Measures Compliance and Disclosure Interpretations.



       Please contact Tracey Houser at 202-551-3736 or Terence O'Brien at
202-551-3355 if
you have questions regarding comments on the financial statements and related
matters.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Industrial Applications and
                                                            Services