December 30, 2024 John Rogers Chief Financial Officer SMITH & NEPHEW PLC Building 5, Croxley Park, Hatters Lane Watford, Hertfordshire WD18 8YE Re: SMITH & NEPHEW PLC Form 20-F filed March 11, 2024 File No. 001-14978 Dear John Rogers: 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