Mail Stop 7010
								January 30, 2006



Martin J. Landon
Vice President and Chief Financial Officer
Kinetic Concepts, Inc.
8023 Vantage Drive
San Antonio, Texas 78230

      Re:	Kinetic Concepts, Inc.
      Form 10-K for Fiscal Year Ended December 31, 2004
		Form 10-Q for Fiscal Quarters Ended September 30, 2005
		File No. 1-09913

Dear Mr. Landon:

      We have reviewed your response 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.  After
reviewing this information, we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-Q for the Period Ended September 30, 2005

Financial Statements - Note 5. Litigation Settlement

1.	We note your response to prior comment 3, however it remains
unclear to us what specific events and circumstances occurred,
from
the date you filed your FY 2004 10K until the date you disclosed
the
settlement with Novamedix, which significantly changed your
assessment of this litigation.  Please tell us:
* The underlying estimates and assumptions you used to determine
the
original range of loss of $3,000,000 to $10,000,000.
* The specific facts and circumstances that resulted in your
original
range of loss being materially inadequate.
* The reasons why you accepted the $75 million settlement.
* The underlying estimates and assumptions you used to determine
you
should accept the settlement.
* The reasons why you retained an independent outside counsel when
you did and the reasons why you did not believe outside counsel
was
necessary any earlier.
* The reasons why you did not disclose the original range of loss
of
$3,000,000 to $10,000,000.
* The reasons why you first disclosed in your 6/30/05 Form 10-Q
that
damages awarded may be significant and why you did not provide any
quantification of the potential damages.
* The reasons why you did not disclose the September 30, 2005
settlement until October 25, 2005.

2.		Based on your current disclosures, it is not clear to us
if
or how the patent infringement settlement with Novamedix may
impact
future results of operations and cash flows.  With a view to
future
disclosure, please tell us the amount of revenues you generated
each
period related to the products that were the subject of this
litigation.  Please also tell us, if and how you expect the
settlement to impact future results and cash flows.

Financial Statements - Note 7. Commitments and Contingencies

3.		Based on your current disclosures is not clear to us how
the pending patent infringement litigation with BlueSky may impact
future results of operations and cash flows.  With a view to
future
disclosure, please tell us the amount of revenues you generated
each
period related to products that are the subject of this
litigation.
Please also help us understand, with additional specificity, how
an
unfavorable resolution of this litigation may impact future
results
and cash flows.

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides any
requested information.  Detailed letters greatly facilitate our
review.  Please understand that we may have additional comments
after
reviewing your responses to our comments.

	You may contact Bret Johnson at (202) 551-3753, Anne
McConnell
at (202) 551-3709 or me at (202) 551-3768 if you have questions
regarding our comments.

Sincerely,



John Cash
Accounting Branch Chief
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Martin Landon
Kinetic Concepts, Inc.
January 30, 2006
Page 1


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE