September 18, 2018

Thad Huston
Chief Financial Officer
LivaNova PLC
20 Eastbourne Terrace
London, United Kingdom
W2 6LG

       Re: LivaNova PLC
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed February 28, 2018
           Form 8-K filed on August 1, 2018
           File No. 001-37599

Dear Mr. Huston:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 8-K filed on August 1, 2018

Exhibit 99.1, page 3

1.    We note that you present the forward looking non-GAAP measure adjusted
diluted
      earnings per share without providing the reconciliation to the most
directly comparable
      GAAP financial measure or the statement that providing such
reconciliation requires
      unreasonable efforts. Refer to Item 10(e)(1)(i)(B) of Regulation S-K and
the guidance in
      Question 102.10 of the Compliance and Disclosure Interpretations on
Non-GAAP
      Financial Measures and revise your future filings to provide the required
information.
 Thad Huston
LivaNova PLC
September 18, 2018
Page 2
2.       On pages 13-16 you present the reconciliations of your non-GAAP
measures to the most
         directly comparable GAAP measures in the form of a full non-GAAP
income statement, a
         presentation that gives greater prominence to the non-GAAP measures.
Refer to the first
         bullet point within Question 102.10 of the Compliance and Disclosure
Interpretations on
         Non-GAAP Financial Measures and revise your presentation in future
filings accordingly.
       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.

        You may contact Tara Harkins at (202) 551-3639 or Lynn Dicker, Senior
Accountant, at
(202) 551-3616 with any questions.



FirstName LastNameThad Huston                               Sincerely,
Comapany NameLivaNova PLC
                                                            Division of
Corporation Finance
September 18, 2018 Page 2                                   Office of
Electronics and Machinery
FirstName LastName