Boston Scientific Corporation
300 Boston Scientific Way
Marlborough, MA 01752
March 30, 2026
Via EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Industrial Applications and Services
100 F Street, NE
Washington, D.C. 20549
Attn: Margaret Sawicki
| Re: | Boston Scientific Corporation |
| Registration Statement on Form S-4 | |
| Filed on February 27, 2026 | |
| File No. 333-293872 | |
| Request for Effectiveness |
Dear Ms. Sawicki,
Reference is made to the Registration Statement on Form S-4 (File No. 333-293872) (the “Registration Statement”) filed by Boston Scientific Corporation (the “Company”) with the U.S. Securities and Exchange Commission on February 27, 2026, as amended on March 30, 2026.
The Company hereby requests that the effective date for the Registration Statement be accelerated to 9:00 a.m., Eastern Time, on April 1, 2026, or as soon as possible thereafter, pursuant to Rule 461 promulgated under the U.S. Securities Act of 1933, as amended.
Please contact Clare O’Brien of Allen Overy Shearman Sterling US LLP at (212) 848-8966 or cobrien@aoshearman.com with any questions you may have concerning this letter or if you require any additional information. We request that we be notified of the effectiveness of the Registration Statement by telephone call to Ms. O’Brien and that such effectiveness also be confirmed in writing.
[Signature Page Follows]
| Sincerely yours, | ||
| Boston Scientific Corporation | ||
|
/s/ Jonathan Monson | ||
| Name: | Jonathan Monson | |
| Title: | Executive Vice President and Chief Financial Officer | |
| cc: | Vance R. Brown – Boston Scientific Corporation |
| Clare O’Brien, Esq. – Allen Overy Shearman Sterling US LLP | |
| Derrick Lott, Esq. – Allen Overy Shearman Sterling US LLP | |
| Richard Alsop, Esq. – Allen Overy Shearman Sterling US LLP | |
| Johanna Roberts – Penumbra, Inc. | |
| Alan Denenburg, Esq – Davis Polk & Wardwell LLP | |
| Michael Diz, Esq. – Davis Polk & Wardwell LLP |