September 21, 2018

Todd W. Garner
Executive Vice President & Chief Financial Officer
CONMED Corporation
525 French Road
Utica, New York 13502

       Re: CONMED Corporation
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed February 26, 2018
           Form 10-Q for the Quarterly Period Ended June 30, 2018
           Filed August 2, 2018
           Form 8-K dated August 1, 2018
           Filed August 2, 2018
           File No. 000-16093

Dear Mr. Garner:

       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 10-Q for the Quarterly Period Ended June 30, 2018

Financial Statements
Note 3. Revenues, page 4

1.    We note on page 5 that the net commission percentage charged under your
agreement
      with Musculoskeletal Transplant Foundation can vary over the term of the
agreement.
      Please tell us the amount of revenue recognized under this agreement
during the six-
      months ended June 30, 2018, and describe to us how you account for the
variability in the
      transaction price over the term of the agreement. In addition, explain to
us the "acquired
 Todd W. Garner
FirstName LastNameTodd W. Garner
CONMED Corporation
Comapany 21, 2018
September NameCONMED Corporation
September 21, 2018 Page 2
Page 2
FirstName LastName
         assets" in this arrangement and the basis for reducing revenues for
the amortization of
         these acquired assets over its expected useful life of 25 years.


2.       We note from the table on page 18 that approximately 20% of your
revenue is related to
         the sale of capital equipment. Please describe to us the material
terms of your capital
         equipment sales contracts and explain how you account for these sales.
In
         addition, describe to us any related contractual agreements to
purchase single-use
         products and stand-ready service agreements and address your
accounting for these
         agreements under ASC 606, with appropriate references to the specific
guidance on which
         you relied.
3.       To help us better understand your accounting for the capital equipment
you loan to
         customers, please address the following:

             Describe to us the significant terms of your agreements with your
customers, including
             the contract period and what happens to the equipment upon
termination of the
             contract.
             Describe to us the minimum purchase requirements, including for
example, whether a
             customer is required to make a minimum number of purchases per
year, a minimum
             number of purchases over the life of the agreement, or a minimum
percentage of its
             overall purchases of the related single-use product from you.
             Clarify for us whether only your single use products can be used
with your loaned
             capital equipment.
             Explain to us your rights to obtain the equipment if your customer
does not meet the
             minimum purchase quantities.
             Tell us who controls and maintains title to the capital equipment
when it is at your
             customer's site.
             Tell us who incurs the costs to service and maintain the capital
equipment while it is at
             your customer's site.
             Tell us the value of the loaned capital equipment at the time it
is placed with the
             customer.
             Tell us where on your income statement you present the amortized
cost of your loaned
             capital equipment.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Consolidated Results of Operations, page 17

4.       We note that on page 18 you present the change in sales 'as reported'
and 'as adjusted' but
         did not provide the reconciliation of the non-GAAP measure to the
comparable GAAP
         measure as required by Item 10(e)(1)(i)(B) of Regulation S-K. Please
revise your future
         filings to comply with that guidance.
 Todd W. Garner
CONMED Corporation
September 21, 2018
Page 3
Form 8-K dated August 1, 2018

Exhibit 99.1, page 1

5.       In the highlights section of your earnings release you disclose that
adjusted gross margin
         increased 190 basis points year over year to 54.6% but you did not
provide the
         reconciliation of the non-GAAP measure to the comparable GAAP measure
as required
         by Item 10(e)(1)(i)(B) of Regulation S-K. Please revise your future
filings to comply with
         that guidance.
       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 Julie Sherman at (202) 551-3640 or Martin James, Senior
Assistant
Chief Accountant, at (202) 551-3671 with any questions.



FirstName LastNameTodd W. Garner                             Sincerely,
Comapany NameCONMED Corporation
                                                             Division of
Corporation Finance
September 21, 2018 Page 3                                    Office of
Electronics and Machinery
FirstName LastName