October 9, 2019

Robert Davis
Senior Vice President and General Counsel
Glaukos Corporation
229 Avenida Fabricante
San Clemente, California 92672

       Re: Glaukos Corporation
           Registration Statement on Form S-4
           Filed September 17, 2019
           File No. 333-233807

Dear Mr. Davis:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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 this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Registration Statement on Form S-4 filed September 17, 2019

Exclusive Forum, page 261

1.     We note that your forum selection provision identifies the Court of
Chancery of the State
       of Delaware as the exclusive forum for certain litigation, including any
"derivative
       action." Please revise your prospectus to clearly and prominently
describe the
       provision. Describe any risks or other impacts on investors. Risks may
include, but are
       not limited to, increased costs to bring a claim and that these
provisions can discourage
       claims or limit investors' ability to bring a claim in a judicial forum
that they find
       favorable. Also disclose whether this provision applies to actions
arising under the
       Securities Act or Exchange Act. In that regard, we note that Section 27
of the Exchange
       Act creates exclusive federal jurisdiction over all suits brought to
enforce any duty or
       liability created by the Exchange Act or the rules and regulations
thereunder, and Section
 Robert Davis
Glaukos Corporation
October 9, 2019
Page 2
      22 of the Securities Act creates concurrent jurisdiction for federal and
state courts over all
      suits brought to enforce any duty or liability created by the Securities
Act or the rules and
      regulations thereunder. If the provision applies to Securities Act
claims, please also revise
      your prospectus to state that there is uncertainty as to whether a court
would enforce such
      provision and that investors cannot waive compliance with the federal
securities laws and
      the rules and regulations thereunder. If this provision does not apply to
actions arising
      under the Securities Act or Exchange Act, please tell us how you will
inform investors in
      future filings that the provision does not apply to any actions arising
under the Securities
      Act or Exchange Act.
      Please contact Thomas Jones at 202-551-3602 or Geoffrey Kruczek, Senior
Attorney, at
202-551-3641 with any other questions.



                                                             Sincerely,
FirstName LastNameRobert Davis
                                                             Division of
Corporation Finance
Comapany NameGlaukos Corporation
                                                             Office of
Manufacturing
October 9, 2019 Page 2
cc:       Barbara L. Borden
FirstName LastName