September 5, 2024

Stuart Drummond
Interim Chief Financial Officer
CUTERA INC
3240 Bayshore Boulevard
Brisbane , California 94005

        Re: CUTERA INC
            Form 10-K for Fiscal Year Ended December 31, 2023
            Filed May 10, 2024
            Form 8-K Filed March 21, 2024
            File No. 000-50644
Dear Stuart Drummond:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 8-K Filed March 21, 2024
Exhibit 99.1

1.     We note your presentation of Adjusted operating income that includes an
adjustment to
       exclude retention plan costs for fiscal year 2023 and for the subsequent
quarterly periods
       in fiscal year 2024. Please tell us how you determined that the
retention plan costs are not
       normal operating costs and are consistent with Question 100.01 of the
Non-GAAP
       Compliance and Disclosure Interpretations. As part of your response,
tell us how these
       retention costs differ from other compensation paid to your employees,
including the
       material terms of the payments and whether any additional services are
required to be
       provided by the employees above and beyond their normal employment.
2.     As previously requested in our letter dated November 4, 2022, please
remove the
       characterization of your separation costs or any other types of costs as
non-recurring
       unless such costs have not occurred in multiple periods and are not
reasonably likely to
       recur within two years. Refer to Rule 100(b) of Regulation G and
Question 102.03 of the
 September 5, 2024
Page 2

       C&DIs on Non-GAAP Financial Measures.
       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.

       Please contact Tracey Houser at 202-551-3736 or Terence O'Brien at
202-551-3355 with
any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Industrial
Applications and
                                                          Services