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                           May 31, 2024

       Christopher Berry
       Chief Accounting Officer
       Davita, Inc.
       2000 16th ST
       Denver, CO 80202

                                                        Re: Davita, Inc.
                                                            Form 10-K For the
Fiscal Year Ended December 31, 2023
                                                            Filed February 14,
2024
                                                            Response Dated May
10, 2024
                                                            File No. 001-14106

       Dear Christopher Berry:

              We have reviewed your May 10, 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 April 11, 2024
       letter.

       Form 10-K For the Fiscal Year Ended December 31, 2023

       Reconciliations of non-GAAP measures, page 72

   1.                                                   We have reviewed your
proposed revised disclosure and response to prior comment 2 and
                                                        have the following
comment. To allow investors to fully assess your non-GAAP
                                                        measures, please
provide a separate footnote for each non-GAAP adjustment that
                                                        includes company
specific information describing the facts and circumstances related to
                                                        the adjustment.
 Christopher Berry
FirstName
Davita, Inc.LastNameChristopher Berry
Comapany
May         NameDavita, Inc.
     31, 2024
May 31,
Page 2 2024 Page 2
FirstName LastName
2.       As a related matter, your adjustment for center closure charges does
not appear consistent
         with Question 100.01 of the Non-GAAP Financial Measures C&DI since the
charges are
         repeatedly occurring over multiple years and are a cash expense
related to your business
         strategy. Please remove the adjustment for center closure charges from
your non-GAAP
         measures in future filings.
Consolidated Financial Statements
Property and equipment, page F-13

3.       We note your revised disclosure and response to prior comment 4.
Please provide us the
         following additional information to help us understand the accounting
for costs incurred
         for the relocations of centers.

                Tell us why your proposed revised disclosure does not state
that development capital
              expenditures includes costs to relocate centers;
                Quantify the amount of development capital expenditures related
to the relocation of
              centers during the two most recent fiscal years and most recent
interim period;
                Tell us whether all relocations result in an increase in
capacity and if all relocations
              result in an increase in revenues;
                Tell us if there are any circumstances in which you expense
costs related to
              relocations; and
                Explain how you concluded that the costs incurred in relocating
centers extend the
              useful life of the underlying assets or improve quantity or
quality of goods or services
              produced by the asset.

       Please contact Michael Fay at 202-551-3812 or Kristin Lochhead at
202-551-3664 if you
have questions regarding comments on the financial statements and related
matters.



                                                                Sincerely,

                                                                Division of
Corporation Finance
                                                                Office of
Industrial Applications and
                                                                Services