August 13, 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 29, 2024
           File No. 001-08597
Dear Brian G. Andrews:

       We have reviewed your July 29, 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 July
16, 2024 letter.

Form 10-K for Fiscal Year Ended October 31, 2023
Note 1. Organization and Significant Accounting Policies
Revenue Recognition

1.     We note from your disclosures in Note 3 to your fiscal year 2022 audited
financial
       statements that Generate Life Sciences recognized $249.5 million in
revenues from
       December 17, 2021 through October 31, 2022, which is 7.5% of fiscal year
2022 net
       sales. As such, we continue to request that you provide comprehensive
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 through
       50-12A and 606-10-50-17, (b) significant judgments for the method used
to recognize
       revenue over time and why the method faithfully depicts the transfer of
the services with
 August 13, 2024
Page 2

       reference to ASC 606-10-50-18, (c) significant judgments made in
evaluating when a
       customer obtains control of a service that is recognized at a point in
time with reference to
       ASC 606-10-50-19 and (d) variable consideration and any other
obligations with
       reference to ASC 606-10-50-20.
Form 8-K Filed May 30, 2024
Exhibit 99.1

2.     We note your response to comment 3 and that in fiscal year 2021, you
immediately
       recognized a GAAP income tax benefit of $1,987.9 million in accordance
with ASU
       2016-16. The non-GAAP intra-entity transfer adjustments made to reflect
amortization of
       the tax benefit over time, rather than when the assets were actually
transferred, have the
       effect of reversing the US GAAP accounting treatment. As a result, the
non-GAAP
       adjustment changes the recognition and measurement principles required
to be applied in
       accordance with US GAAP and accordingly results in non-GAAP measures
with
       individually tailored accounting principles. Please remove this
adjustment from your
       future non-GAAP presentations.
       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