United States securities and exchange commission logo




                                                                                
                     March 15, 2024

       Patrick Williams
       Chief Financial Officer
       STAAR Surgical Company
       25651 Atlantic Ocean Drive
       Lake Forest, California 92630

                                                        Re: STAAR Surgical 
Company
                                                            Form 10-Q for 
Period Ended September 30, 2023
                                                            Form 8-K Filed 
November 1, 2023
                                                            File No. 000-11634

       Dear Patrick Williams:

              We have completed our review of your filings. 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.



                                                                                
                     Sincerely,

                                                                                
                     Division of Corporation Finance
                                                                                
                     Office of Industrial Applications and
                                                                                
                     Services