March 27, 2025

Shubham Maheshwari
Chief Financial Officer
Varex Imaging Corporation
1678 S. Pioneer Road
Salt Lake City, Utah 84104

       Re: Varex Imaging Corporation
           Form 10-K for the Fiscal Year Ended September 27, 2024
           Filed November 19, 2024
           Form 8-K Furnished November 19, 2024
           File No. 001-37860
Dear Shubham Maheshwari:

       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 Furnished November 19, 2024
Exhibit 99.1

1.     We note your non-GAAP measures include an adjustment for "other
non-operational
       costs." Please tell us the amount and nature of each material component
of this
       adjustment in fiscal year 2024 and how you determined that they were not
normal
       and recurring operating expenses necessary to operate your business.
Specifically
       address the propriety of adjusting for inventory write-downs of
discontinued
       products. See Question 100.01 of the Compliance and Disclosure
Interpretations
       on Non-GAAP Financial Measures. Please present a separate line item for
any
       individual amounts that are material in future filings.
Form 10-K for the Fiscal Year Ended September 27, 2024
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
 March 27, 2025
Page 2

Comparison of Results of Operations for Fiscal Years 2024 and 2023, page 31

2.     Where you describe two or more business reasons that contributed to a
material
       change in a financial statement line item between periods, please
quantify, where
       possible, the extent to which each factor contributed to the overall
change in that line
       item, including any offsetting factors. In addition, where you identify
intermediate
       causes of changes in your operating results, also describe the reasons
underlying the
       intermediate causes. We note your disclosures that the changes in
segment revenues,
       revenues by region, and segment gross profit from fiscal year 2023 to
fiscal year 2024
       were due to lower sales in your China business and changes in sales of
various
       products. To the extent possible, quantify the impact of each
contributing factor in
       dollars and/or percentage, expand on the reasons driving these changes,
and provide
       greater transparency into the material components and potential
variability of your
       revenues and gross profit.
Liquidity and Capital Resources
Cash Flows, page 34

3.     Please provide a more informative analysis and discussion of changes in
operating,
       investing and financing cash flows for each period presented. In doing
so, explain the
       underlying reasons and implications of material changes between periods
to provide
       investors with an understanding of trends and variability in cash flows.
Also provide
       an analysis of any known trends and uncertainties that will result in or
that are
       reasonably likely to result in a material increase or decrease in your
liquidity. Ensure
       your discussion and analysis is not merely a recitation of changes
evident from the
       financial statements. Refer to Item 303(a) of Regulation S-K and Section
IV.B of SEC
       Release No. 33-8350.
Critical Accounting Estimates
Goodwill and Intangible Assets, page 36

4.     We note that you conducted a quantitative goodwill impairment test
during the fourth
       quarter of fiscal 2024 due to indicators of possible impairment. Please
disclose
       whether any of your reporting units are at risk of failing the goodwill
impairment
       test. A reporting unit is at risk of failing the impairment test if it
has a fair value that is
       not substantially in excess of carrying value. If no reporting units are
at risk based on
       your most recent impairment test, disclose such information to your
readers as we
       believe it provides them with valuable information in assessing the
sensitivity of your
       goodwill to future impairment. Alternatively, if a reporting unit is at
risk of failing the
       impairment test and a material impairment charge could occur, please
disclose the
       following:
           The percentage by which fair value exceeded carrying value as of the
date of the
           most recent test;
           The amount of goodwill allocated to the reporting unit;
           A description of the methods and key assumptions used and how the
key
           assumptions were determined;
           A discussion of the degree of uncertainty associated with the key
 March 27, 2025
Page 3

           assumptions. The discussion regarding uncertainty should provide
specifics to the
           extent possible (e.g., the valuation model assumes recovery from a
business
           downturn within a defined period of time); and
             A description of potential events and/or changes in circumstances
that could
           reasonably be expected to negatively affect the key assumptions.
17. Segment Information, page F-38

5.     Although we note you disclose revenues by segment and geography on page
F-39,
       please tell us how you considered further disaggregation of your
revenues pursuant to
       ASC 606-10-50-5 and ASC 606-10-55-89 through 55-91, such as by modality,
       vertical, sales channel, customer type, and timing of revenue
recognition. We note that
       you provide pie charts reflecting segment revenue by modality and
vertical in your
       earnings presentation for the first quarter of fiscal year 2025. See
also the guidance in
       ASC 280-10-50-40.
6.     We note your page 31 disclosure regarding the impact of your China
business on the
       decrease in Medical segment revenues. We further note you discuss your
sales in
       China during the earnings call for the first quarter of fiscal year
2025. Pursuant to
       ASC 280-10-50-41, please revise future filings to disclose revenues from
external
       customers attributed to each individual foreign country, if material.
7.     We note your disclosure on page 13 that one customer accounted for 18%
of your
       fiscal year 2024 revenue. Please revise future filings to disclose the
identity of the
       segment(s) reporting the revenues from such customer pursuant to ASC
280-10-50-
       42.
        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 Stephany Yang at 202-551-3167 or Andrew Blume at
202-551-3254
with any questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Manufacturing