September 5, 2024

Maggie Yuen
Chief Financial Officer
Penumbra, Inc.
One Penumbra Place
Alameda , CA 94502

        Re: Penumbra, Inc.
            Form 10-K for Fiscal Year Ended December 31, 2023
            Form 10-Q for Fiscal Quarter Ended June 30, 2024
            Form 8-K filed July 30, 2024
            File No. 001-37557
Dear Maggie Yuen:

       We have limited our review of your filing to the financial statements
and related
disclosures 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.

Form 10-Q for Fiscal Quarter Ended June 30, 2024
Note 4. Impairment of Immersive Healthcare Asset Group, page 12

1.     We note you reported impairment losses on inventory, finite-lived
intangibles, and
       property and equipment for your Immersive Healthcare business since the
company made
       the strategic decision to explore its alternative avenue during the
three months ended June
       30, 2024. Please provide us an analysis of your timeline for making
these strategic moves
       and your considerations for meeting the criteria to report your
Immersive Healthcare
       business as held for sale under ASC 360-10-45 as of December 31, 2023
and June 30,
       2024. In that regard, we also note that you began to classify your end
markets based on
       the type of procedure being performed, and therefore divided Immersive
Healthcare as a
       separate market/business beginning with the three months ended December
31, 2023.
 September 5, 2024
Page 2
Form 8-K filed July 30, 2024
Exhibit 99.1, page 1

2.     Within the header of your earnings release you discussed the non-GAAP
measures
       Adjusted EBITDA and adjusted EBITDA margin without also discussing the
most
       comparable GAAP measure of net (loss) income and net (loss) income
margin. Please
       revise your header and presentations in future filings accordingly to
comply with Item
       10(e)(1)(i)(A) of Regulation S-K and Question 102.10(a) of the
Division's Compliance
       & Disclosure Interpretations (   C&DIs   ) on Non-GAAP Financial
Measures.
3.     We note that several of your non-GAAP performance measures include an
adjustment of
       $33.4 million for an inventory write-down of Immersive Healthcare asset
group and such
       charge was recorded as cost of revenue. With reference to ASC
420-10-S99-3, please tell
       us your consideration of the guidance in Question 100.01 of the
Division's Compliance
       and Disclosure Interpretations ("C&DIs") on Non-GAAP Financial Measures.

       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.

       Please contact Christie Wong at 202-551-3684 or Li Xiao at 202-551-4391
with any
questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Industrial
Applications and
                                                          Services