Medtronic CORRESP Correspondence with SEC

February 7, 2006

Mr. Jay Webb
Mail Stop 6010
Securities and Exchange Commission
100 F Street, NE
Washington, D. C. 20549

Re:	Medtronic, Inc.
	Form 10-K for the year ended April 29, 2005
	Filed June 29, 2005
	File No. 001-7707

Dear Mr. Webb:

     As a result of our recent phone call with you, Ms. Angela Crane and Ms. Julie Sherman on January 30, 2006, Medtronic, Inc. (the “Company”) would like to revise its responses filed on December 23, 2005 and January 20, 2006 to the first bullet point of Question 3 raised in your letter dated December 14, 2005. We believe that other comments raised in your letter dated December 14, 2005 have been addressed by our prior responses filed on December 23, 2005 and January 20, 2006.

Form 8-K dated November 16, 2005

3. With respect to the non-GAAP disclosures, please respond to the following:

• We note that your reconciliation of the non-GAAP information as required by Regulation G is in the form of a statement of operations. We do not believe that the presentation of a non-GAAP statement of operations is appropriate unless all disclosures required by Item 10(e)(1)(i) of Regulation S-K are included for each separate non-GAAP measure. Please delete this presentation from all future Forms 8-K. If you continue to present non-GAAP information, Item 2.02 of Form 8-K requires that disclosures “furnished” include information that complies with the disclosure requirements of Item 10(e)(1)(i) of Regulation S-K. Accordingly, in addition to the reconciliation for each non-GAAP measure, you must also provide statements disclosing the reasons why management believes presentation ofeach of the individual non-GAAP measures provide useful information to investors regarding your financial condition and results of operations. These disclosures should bespecific andsubstantive to each individual measure. Refer to SEC Release 33-8176 and also Question 8 of the FAQ Regarding the Use of Non-GAAP Financial

Mr. Jay Webb
February 7, 2006
Page 2 of 2

Measures, dated June 13, 2003. Please confirm that you will revise your Forms 8-K in future periods to provide all of the disclosures required by Item 10(e)(1)(i) for each non-GAAP measure presented. Provide us with a full sample of your proposed disclosure.

Response:

We will revise our non-GAAP disclosure in future filings in accordance with your comments. A revised full sample of our proposed disclosure based upon our Form 8-K dated November 16, 2005 is attached to this letter for your review.

     If you have any questions regarding these matters, please contact me (763-505-1510) or, in my absence, Gary Ellis, Senior Vice President and Chief Financial Officer (763-505-2770).

Sincerely,

/s/ Thomas M. Tefft
Thomas M. Tefft
Vice President and Corporate Controller
Medtronic, Inc.
World Headquarters
710 Medtronic Parkway
Minneapolis, MN 55432-5604

Phone: (763) 505-1510
Fax: (763) 505-2808
E-Mail: tom.tefft@medtronic.com

cc: Julie Sherman

SAMPLE

EXHIBIT 99.1

Contacts:

Rachael Scherer

Medtronic Investor Relations

763-505-2694

Rob Clark

Medtronic Public Relations

763-505-2635

Yvan Deurbroeck

Medtronic International

+41 21 802 7574

FOR IMMEDIATE RELEASE

MEDTRONIC REPORTS SECOND QUARTER REVENUE GROWTH OF 15%
AND 23% GROWTH IN ADJUSTED DILUTED EPS

As Reported Diluted EPS of $0.67 Increased 52%

• Implantable Cardioverter Defibrillator (ICD) Revenues Grew 34%; Worldwide Market Share Continued to Increase

• Spinal Continued Track Record of Strong Growth with Revenues Up 20%

• Diabetes Revenues Grew 17%

• Quarterly Vascular Revenues Reflect Positive Acceptance of the Endeavor Drug Eluting Coronary Stent in Europe

• Favorable Resolution of Internal Revenue Service (IRS) Tax Audit Resulted in $225 Million Tax Reversal and Tax Rate Reduction

MINNEAPOLIS — November 16, 2005 —Medtronic, Inc. (NYSE: MDT) today announced record revenues for the quarter ended October 28, 2005 of $2.765 billion, a 15 percent increase over the $2.400 billion recorded in the second quarter of fiscal year 2005. As reported, second quarter net earnings were $816.5 million or $0.67 per diluted share, an increase of 52 percent over the prior year second quarter. Second quarter adjusted net earnings of $657.1 million, or $0.54 per diluted share, increased 23 percent over net earnings of $535.7 million and $0.44 per diluted share recorded in the same period last year.

“Balanced growth across the corporation was again led by implantable defibrillators and spinal products”, said Art Collins, chairman and chief executive officer of Medtronic. “Very solid growth momentum has continued throughout the year and reflects the impact of the investments which have been made and that are continuing. As a result, the corporation is well positioned to maintain strong financial performance going forward.”

Factors to Consider When Reviewing Financial Performance

During the second quarter, Medtronic recorded a net after-tax, benefit of $159.4 million, which included a pre-tax $100.0 million donation ($65.6 million after-tax) to the Medtronic Foundation and a $225.0 million tax benefit associated with favorable resolution of field audits with the Internal Revenue Service (IRS) involving fiscal years 1997 through 2002. As a result of these finalized field audits with the IRS, Medtronic’s

effective tax rate for the full fiscal year 2006, before these items, is expected to be reduced to 26 percent from 28 percent. The effective rate reflected in the second quarter has been adjusted to annualize this new effective tax rate. Reflecting the strengthening dollar, foreign currency translation had a negative effect on second quarter revenues of $3.3 million compared to the prior year second quarter.

Cardiac Rhythm Management Business

Cardiac Rhythm Management (CRM) quarterly revenues were $1.289 billion, representing growth of 17 percent over the same period last fiscal year. ICD revenues were $733 million in the quarter, a 34 percent increase over the same period last fiscal year. ICD revenue gains underscore the strength of Medtronic’s ICD product line and sales and support teams. Market share gains in the quarter also reflect, in part, the changing competitive dynamics in the marketplace. Quarterly pacing revenues were $459 million in the quarter, up five percent over the same period last year. This reflects a return to growth in pacing driven by new products released in the previous two quarters. Medtronic’s Emergency Response Systems business reported revenues of $81 million, a decrease of 21 percent, which was the result of vendor supply issues. CRM highlights included:

• Medtronic’s InSync Sentry™ CRT-D system, with OptiVol™ Fluid Status Monitoring, continued to be well received by physicians and now represents the majority of Medtronic CRT-D units sold worldwide. These products, combined with the recently released EnRhythm ICD and Intrinsic families, helped drive worldwide and U.S. ICD market share.

• The introduction of the EnRhythm^® pacemaker with the unique Managed Ventricular Pacing (MVP) feature has contributed to improved U.S. pacing market. In addition, global pacing revenue growth benefited from Japanese regulatory approval of the Kappa^® 900 family during the quarter.

• Medtronic’s Pre-Market Approval (PMA) submission for the Chronicle^® implantable hemodynamic monitor has been accepted and granted “expedited review” status by the U.S. Food and Drug Administration (FDA). The PMA will also support Chronicle™ ICD — a Chronicle^® device with ICD therapy.

• The company announced the approval of its CardioSight™ Service, an in-clinic data access tool available to physicians treating heart failure patients.

• The Medtronic CareLink^® Network continued to expand, surpassing the milestone of 50,000 patients who are now being monitored by over 600 clinics.

Spinal, ENT and Navigation Businesses

Spinal / Ear, Nose and Throat (ENT) / Navigation revenues for the quarter were $603 million, representing 19 percent growth over the same period last fiscal year. Spinal revenues of $516 million increased 20 percent over the same period last fiscal year maintaining a track record of strong growth and market share improvement. Highlights included:

• Medtronic filed a PMA for AMPLIFY™ rhBMP-2, which has a different formulation and carrier of rhBMP-2 designed specifically for posterolateral applications. Spinal biologics revenues increased in excess of 30% over the same period last fiscal year.

• In markets outside the United States, Medtronic’s portfolio of dynamic stabilization products, which includes the DIAM™ System, the MAVERICK™ and O-MAV™ Artificial Lumbar Discs and the PRESTIGE^® LP and BRYAN^®

	Cervical Discs, continued to gain momentum and collectively hold the number one market position in Europe.
•	During the quarter, several innovative new products were introduced, including the CD HORIZON Sextant® II, a percutaneous thoracolumbar stabilization system; METRX™ II, a streamlined microdiscectomy set; and TSRH Silo®, a side-loading thoracolumbar stabilization system.

Neurological and Diabetes Businesses

Neurological and Diabetes quarterly revenues of $487 million increased 13 percent over the same quarter one year ago. Total Neurological revenues were $309 million in the quarter, an 11 percent growth over the same quarter last year. Diabetes revenues were $178 million, a 17 percent increase over the same quarter last fiscal year. Highlights from the quarter included:

• Revenues from the RESTORE™ Rechargeable Neurostimulation System benefited from the September introduction of a flexible extender, which allows for easier device replacement. RESTORE is estimated to hold the leading market share position in the rapidly growing rechargeable segment of the market.

• In August, Medtronic acquired Image-Guided Neurologics Inc. (IGN), a privately held company specializing in precision navigation and delivery technologies for brain surgery.

• The company initiated a controlled market release of the Guardian^® RT Continuous Glucose Monitoring System in the U.S., Canada and Europe. The system displays real-time glucose readings every five minutes and alarms when glucose levels become too high or low. Diabetes patients can now intervene earlier to maintain healthy glucose control, and print records for follow-up discussions with their healthcare providers.

Vascular Business

Vascular revenues of $225 million for the quarter represented 12 percent growth over the same period last fiscal year. Vascular highlights included:

• The Endeavor™ Drug Eluting Coronary Stent was commercially released in over 85 countries outside the U.S. Market share increased as revenues of $36 million were recorded.

• U.S. ENDEAVOR clinical trials were reported upon and enrollment gained momentum over the course of the quarter. Clinical results presented at the European Society of Cardiology (ESC) and the Transcatheter Cardiovascular Therapeutics (TCT) conference further expanded the medical evidence supporting the clinical performance of the Endeavor™ Drug Eluting Coronary Stent. In addition, the company filed its first PMA module for Endeavor with the U.S. FDA in early October and enrollment in the ENDEAVOR IV clinical trial is progressing as planned. The company remains on track for targeted U.S. approval in calendar year 2007.

• Endovascular product lines, including the AneuRx^® and Talent™ Stent Grafts for the treatment of abdominal and thoracic aortic aneurysms (AAA/TAA), grew 11% worldwide and maintained market leadership positions.

Cardiac Surgery Business

Cardiac Surgery revenues of $161 million in the quarter grew one percent over the same period last fiscal year. Highlights from the quarter included:

• The Mosaic^® and Mosaic^® Ultra Heart Tissue Valves continued to drive growth in Medtronic’s tissue heart valve product line.

• Cardiac Surgery Technologies (CST) revenues were led by market acceptance of the Cardioblate^® BP Surgical Ablation Systems, which continues to be enhanced by the new Cardioblate^® BP2 system.

Medtronic, Inc., headquartered in Minneapolis, is the world’s leading medical technology company, alleviating pain, restoring health and extending life for people with chronic disease. Its Internet address iswww.medtronic.com.

Webcast Information

Medtronic will host a webcast today, November 16 at 4:30 pm EST (3:30 CST), to provide information about its businesses for the public, analyst and news media. This quarterly webcast can be accessed by clicking on the Investor Relations link on the Medtronic home page atwww.medtronic.com., and this earnings release will be archived atwww.medtronic.com/newsroom. Within 24 hours, a replay of the webcast and a transcript of the company’s prepared remarks will be available in the “Presentations & Transcripts” section of the Investor Relations homepage.

This press release contains forward-looking statements, including statements regarding clinical trials, which are subject to risks and uncertainties, such as competitive factors, difficulties and delays inherent in the development, manufacturing, marketing and sale of medical products, government regulation, general economic conditions and others described in Medtronic’s Annual Report onForm 10-K for the year ended April 29, 2005. Actual results may differ materially from anticipated results. Medtronic does not undertake to update its forward-looking statement.

The BRYAN^® Cervical Disc System incorporates technology developed by Gary K. Michelson, M.D.

MEDTRONIC, INC.
CONDENSED CONSOLIDATED BALANCE SHEETS
(Unaudited)

	October 28,			April 29,
	2005			2005
	(in millions of dollars,
	except per share data)
ASSETS
Current assets:
Cash and cash equivalents	$	1,947.8		$	2,232.2
Short-term investments		2,229.5			1,159.4
Accounts receivable, less allowances of $175.5 and $174.9, respectively.		2,316.2			2,292.7
Inventories		1,126.6			981.4
Deferred tax assets, net		81.5			385.6
Prepaid expenses and other current assets		417.4			370.2
Total current assets		8,119.0			7,421.5
Property, plant and equipment		3,707.2			3,628.6
Accumulated depreciation		(1,825.0	)		(1,769.3	)
Net property, plant and equipment		1,882.2			1,859.3
Goodwill		4,331.1			4,281.2
Other intangible assets, net		1,632.8			1,018.0
Long-term investments		1,346.0			1,565.7
Other assets		456.4			471.7
Total assets	$	17,767.5		$	16,617.4
LIABILITIES AND SHAREHOLDERS’ EQUITY
Current liabilities:
Short-term borrowings	$	2,835.1		$	478.6
Accounts payable		340.7			371.8
Accrued compensation		598.3			542.2
Accrued income taxes		674.7			923.3
Other accrued expenses		450.3			1,064.1
Total current liabilities		4,899.1			3,380.0
Long-term debt		1,001.2			1,973.2
Deferred tax liabilities, net		370.9			478.1
Long-term accrued compensation		171.9			157.9
Other long-term liabilities		190.7			178.7
Total liabilities		6,633.8			6,167.9
Commitments and contingencies		—			—
Shareholders’ equity:
Preferred stock — par value $1.00		—			—
Common stock — par value $0.10		120.7			121.0
Retained earnings		10,843.8			10,178.5
Accumulated other non-owner changes in equity		169.2			150.0
Total shareholders’ equity		11,133.7			10,449.5
Total liabilities and shareholders’ equity	$	17,767.5		$	16,617.4

MEDTRONIC, INC.
CONDENSED CONSOLIDATED STATEMENTS OF EARNINGS
(Unaudited)
(in millions, except per share data)

	Three months ended						Six months ended
	October 28, 2005			October 29, 2004			October 28, 2005			October 29, 2004
Net sales	$	2,765.4		$	2,399.8		$	5,455.8		$	4,745.9
Costs and expenses:
Cost of products sold		694.8			584.8			1,348.6			1,135.1
Research and development expense		275.4			232.7			538.6			462.4
Selling, general, and administrative expense		903.2			772.0			1,785.6			1,541.7
Special charges		100.0			—			100.0			—
Purchased in-process research and development (IPR&D)		—			—			363.8			—
Other expense, net		40.5			62.9			91.5			117.5
Interest income		(13.4	)		(7.1	)		(28.8	)		(11.4	)
Total costs and expenses		2,000.5			1,645.3			4,199.3			3,245.3
Earnings (loss) before income taxes		764.9			754.5			1,256.5			1,500.6
Provision for income taxes		(51.6	)		218.8			119.4			435.2
Net earnings	$	816.5		$	535.7		$	1,137.1		$	1,065.4
Earnings (loss) per share:
Basic	$	0.68		$	0.44		$	0.94		$	0.88
Diluted	$	0.67		$	0.44		$	0.93		$	0.87
Weighted average shares outstanding:
Basic		1,208.6			1,209.5			1,209.6			1,209.3
Diluted		1,222.5			1,221.4			1,222.4			1,221.2

SAMPLE

MEDTRONIC, INC.
RECONCILIATION OF CONSOLIDATED GAAP NET EARNINGS
TO CONSOLIDATED ADJUSTED NET EARNINGS
(Unaudited)
(in millions, except per share data)

	Three months ended			Three months ended
	October 28, 2005			October 29, 2004
Net earnings, as reported	$	816.5		$	535.7
Special charges		65.6	(a)		—
Income tax adjustments		(225.0)	(b)		—
Adjusted net earnings	$	657.1		$	535.7

MEDTRONIC, INC.
RECONCILIATION OF CONSOLIDATED GAAP DILUTED EPS
TO CONSOLIDATED ADJUSTED DILUTED EPS
(Unaudited)

	Three months ended			Three months ended
	October 28, 2005			October 29, 2004
Diluted EPS, as reported	$	0.67		$	0.44
Special charges		0.05	(a)		—
Income tax adjustments		(0.18)	(b)		—
Adjusted diluted EPS	$	0.54		$	0.44

(a)

The $65.6 million ($0.05 per share) special charge represents an after-tax charitable donation ($100.0 million pre-tax) made to The Medtronic Foundation. In addition to disclosing special charges that are determined in accordance with U.S. generally accepted accounting principles (GAAP), Medtronic management believes that in order to properly understand its short-term and long-term financial trends, investors may find it useful to consider the impact of excluding this donation. The Company has not made a similar contribution to The Medtronic Foundation since fiscal year 2002. Management believes that this non-GAAP financial measure provides useful information to investors regarding the underlying business trends and performance of the Company’s ongoing operations and is useful for period over period comparisons of such operations. Medtronic management eliminates this donation when evaluating the operating performance of the Company. Investors should consider this non-GAAP measure in addition to, and not as a substitute for, financial performance measures prepared in accordance with GAAP. In addition, this non-GAAP financial measure may not be the same as similar measures presented by other companies.

(b)

The $225.0 million ($0.18 per share) tax adjustment represent a $225.0 million tax benefit associated with the reversal of reserves resulting from favorable agreements reached with the IRS involving the review of fiscal years 1997 through 2002 domestic income tax returns. In addition to disclosing the provision for income taxes that is determined in accordance with GAAP, Medtronic management believes that in order to properly understand its short-term and long-term financial trends, investors may find it useful to consider the impact of excluding this tax adjustment. Management believes that this non-GAAP financial measure provides useful information to investors regarding the underlying business trends and performance of the Company’s ongoing operations and is useful for period over period comparisons of such operations, specifically the effective tax rate. Medtronic management eliminates this tax adjustment when evaluating the operating performance of the Company. Investors should consider this non-GAAP measure in addition to, and not as a substitute for, financial performance measures prepared in accordance with GAAP. In addition, this non-GAAP financial measure may not be the same as similar measures presented by other companies.

SAMPLE

MEDTRONIC, INC.
RECONCILIATION OF CONSOLIDATED GAAP NET EARNINGS
TO CONSOLIDATED ADJUSTED NET EARNINGS
(Unaudited)
(in millions, except per share data)

	Six months ended			Six months ended
	October 28, 2005			October 29, 2004
Net earnings, as reported	$	1,137.1		$	1,065.4
Special charges		65.6	(a)		—
IPR&D charges		295.3	(b)		—
Income tax adjustments		(225.0)	(c)		—
Adjusted net earnings	$	1,273.0		$	1,065.4

MEDTRONIC, INC.
RECONCILIATION OF CONSOLIDATED GAAP DILUTED EPS
TO CONSOLIDATED ADJUSTED DILUTED EPS
(Unaudited)

	Six months ended			Six months ended
	October 28, 2005			October 29, 2004
Diluted EPS, as reported	$	0.93		$	0.87
Special charges		0.05	(a)		—
IPR&D charges		0.24	(b)		—
Income tax adjustments		(0.18)	(c)		—
Adjusted diluted EPS	$	1.04		$	0.87

(a)	The $65.6 million ($0.05 per share) special charge represents an after-tax charitable donation ($100.0 million pre-tax) made to The Medtronic Foundation. In addition to disclosing special charges that are determined in accordance with U.S. generally accepted accounting principles (GAAP), Medtronic management believes that in order to properly understand its short-term and long-term financial trends, investors may find it useful to consider the impact of excluding this donation. The Company has not made a similar contribution to The Medtronic Foundation since fiscal year 2002. Management believes that this non-GAAP financial measure provides useful information to investors regarding the underlying business trends and performance of the Company’s ongoing operations and is useful for period over period comparisons of such operations. Medtronic management eliminates this donation when evaluating the operating performance of the Company. Investors should consider this non-GAAP measure in addition to, and not as a substitute for, financial performance measures prepared in accordance with GAAP. In addition, this non-GAAP financial measure may not be the same as similar measures presented by other companies.
(b)	The $295.3 million ($0.24 per share) after-tax IPR&D charge ($363.8 million pre-tax) represents the cumulative impact of pre-tax charges of $168.7 million related to a technology acquired through the purchase of Transneuronix, Inc. that had not yet reached technological feasability and had no future alternative use, $175.1 million related to the purchase of spinal technology based devices owned by Gary K. Michelson, M.D. and Karlin Technology, Inc. that had not yet reached technological feasability and had no future alternative use, and $20.0 million related to a cross-licensing agreement with NeuroPace, Inc. for patent and patent applications on products that had not yet reached technological feasability and had no future alternative use, collectively the IPR&D charges. In addition to disclosing IPR&D that is determined in accordance with GAAP, Medtronic managment believes that in order to properly understand its short-term and long-term financial trends, investors may find it useful to consider the impact of excluding these IPR&D charges. These IPR&D charges resulted from facts and circumstances that vary in frequency and/or impact on continuing operations. Management believes that this non-GAAP financial measure provides useful information to investors regarding the underlying business trends and performance of the Company’s ongoing operations and is useful for period over period comparisons of such operations. Medtronic management eliminates these IPR&D charges when evaluating the operating performance of the Company. Investors should consider this non-GAAP measure in addition to, and not as a substitute for, financial performance measures prepared in accordance with GAAP. In addition, this non-GAAP financial measure may not be the same as similar measures presented by other companies.
(c)	The $225.0 million ($0.18 per share) tax adjustment represents a $225.0 million tax benefit associated with the reversal of reserves resulting from favorable agreements reached with the IRS involving the review of fiscal years 1997 through 2002 domestic income tax returns. In addition to disclosing the provision for income taxes that is determined in accordance with GAAP, Medtronic management believes that in order to properly understand its short-term and long-term financial trends, investors may find it useful to consider the impact of excluding this tax adjustment. Management believes that this non-GAAP financial measure provides useful information to investors regarding the underlying business trends and performance of the Company’s ongoing operations and is useful for period over period comparisons of such operations, specifically the effective tax rate. Medtronic management eliminates this tax adjustment when evaluating the operating performance of the Company. Investors should consider this non-GAAP measure in addition to, and not as a substitute for, financial performance measures prepared in accordance with GAAP. In addition, this non-GAAP financial measure may not be the same as similar measures presented by other companies.

MEDTRONIC, INC.
REVENUE BY OPERATING SEGMENT
(Unaudited)

($ millions)

	FY 05		FY 05		FY 05		FY 05		FY 05		FY 06		FY 06			FY 06		FY 06		FY 06
	QTR 1		QTR 2		QTR 3		QTR 4		TOTAL		QTR 1		QTR 2			QTR 3		QTR 4		TOTAL
REPORTED REVENUE :
CARDIAC RHYTHM MANAGEMENT	$	1,097	$	1,104	$	1,150	$	1,265	$	4,616	$	1,268	$	1,289		$	—	$	—	$	2,557
Low Power Pacing		451		438		431		436		1,756		446		459			—		—		905
High Power Defibrillation		551		546		598		684		2,379		718		733			—		—		1,451
Emergency Response Systems		79		104		104		126		413		87		81			—		—		168
Other		16		16		17		19		68		17		16			—		—		33
SPINAL, ENT & NAVIGATION	$	484	$	506	$	536	$	599	$	2,125	$	589	$	603		$	—	$	—	$	1,192
Spinal Constructs		317		332		343		380		1,372		376		382			—		—		759
Spinal Biologics		89		99		107		118		413		128		134			—		—		261
Ear, Nose & Throat (ENT)		58		55		61		67		241		65		64			—		—		129
Navigation		20		20		25		34		99		20		23			—		—		43
NEUROLOGICAL and DIABETES	$	408	$	430	$	460	$	496	$	1,794	$	463	$	487		$	—	$	—	$	950
Neurological		170		179		184		206		739		186		204			—		—		389
Gastroenterology & Urology		42		45		49		52		188		49		48			—		—		97
Neurologic Technologies		50		53		56		59		218		55		57			—		—		112
Diabetes		146		153		171		179		649		173		178			—		—		352
VASCULAR	$	196	$	201	$	221	$	233	$	851	$	205	$	225		$	—	$	—	$	430
Stents		71		78		86		82		317		65		90			—		—		155
Other Coronary		71		71		77		89		308		81		78			—		—		160
Endovascular/Peri pheral		54		52		58		62		226		59		57			—		—		115
CARDIAC SURGERY	$	161	$	159	$	164	$	185	$	669	$	165	$	161		$	—	$	—	$	327
Heart Valves		56		54		56		64		230		58		56			—		—		114
Perfusion		79		79		80		89		327		79		78			—		—		157
Cardiac Surgery Technologies		26		26		28		32		112		28		27			—		—		56
TOTAL	$	2,346	$	2,400	$	2,531	$	2,778	$	10,055	$	2,690	$	2,765		$	—	$	—	$	5,456
ADJUSTMENTS :
CURRENCY(1)		35		40		59		32	$	166		26		(3	)					$	23
COMPARABLE OPERATIONS(1)	$	2,311	$	2,360	$	2,472	$	2,746	$	9,889	$	2,664	$	2,768		$	—	$	—	$	5,433

(1)

— Medtronic management believes that in order to properly understand Medtronic’s short-term and long-term financial trends, investors may wish to consider the impact of foreign currency translation on revenue. In addition, Medtronic management uses results of operations before currency translation to evaluate the operational performance of the Company and as a basis for strategic planning. Investors should consider these non-GAAP measures in addition to, and not as a substitute for, financial performance measures prepared in accordance with GAAP.

Note: The data in this schedule has been intentionally rounded to the nearest million and therefore the quarterly revenues may not sum to the fiscal year to date revenues.