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                             March 30, 2022

       Joseph Busky
       Chief Executive Officer
       Coronado Topco, Inc.
       1001 Route 202
       Raritan, NJ 08869

                                                        Re: Coronado Topco,
Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-4
                                                            Filed March 14,
2022
                                                            File No. 333-262434

       Dear Mr. Busky:

             We have reviewed your amended registration statement 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 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.
Unless we note
       otherwise, our references to prior comments are to comments in our March
1, 2022 letter.

       Amendment No. 1 to Registration Statement on Form S-4

       Risk Factors
       Risk Relating to the Combinations
       The Topco Bylaws will designate the Court of Chancery of the State of
Delaware (the Court of
       Chancery) as the sole and exclusive forum...., page 40

   1.                                                   We note your response
to comment 4. With regard to the federal forum provision, please
                                                        also disclose that
investors cannot waive compliance with the federal securities laws and
                                                        the rules and
regulations thereunder.
       Unaudited Pro Forma Combined Financial Information, page 76

   2.                                                   We note your revisions
in response to prior comment 6, which included changing the title
 Joseph Busky
FirstName  LastNameJoseph Busky
Coronado Topco,  Inc.
Comapany
March      NameCoronado Topco, Inc.
       30, 2022
March2 30, 2022 Page 2
Page
FirstName LastName
         of the pro forma line item from "Cost of revenue excluding
amortization of intangible
         assets" to "Cost of revenue." However, it appears that Ortho's Cost of
revenue line
         item still excludes amortization for intangibles and that you continue
to adjust Quidel's
         Cost of revenues to exclude amortization for intangibles. Please
revise your Cost of
         revenue line item to accurately reflect its composition by identifying
the components
         excluded.
Business of Ortho
Ortho's Competitive Strengths, page 175

3.       We note your response to comment 9, which we reissue in part. Please
place your selected
         disclosure in appropriate context with reference to the material terms
of your agreement
         with Creative Testing Solutions, including quantification of the
benefits and obligations,
         term and termination provisions. Disclosure of material terms is not
contingent on a
         determination that the agreement is required to be filed.
4.       We note your response to comment 10, which we reissue in part. Please
revise to describe
         and quantify the benefits and obligations under your agreement with
Quotient and disclose
         the term and termination provisions. Disclosure of material terms is
not contingent on a
         determination that the agreement is required to be filed. We note on
pages 202 and
         205 that you describe a "non-refundable upfront payment of $7.5
million" connected to
         this agreement, but in your correspondence you also suggest that this
payment was
         contingent on the achievement of "certain milestones." Please clarify
the nature of this
         payment.
Collaboration Arrangements, page 188

5.       We note your response to comment 13. Please revise to describe and
quantify the benefits
         and obligations under the collaboration agreement with Grifols and
disclose the term and
         termination provisions. Disclosure of material terms is not contingent
on a determination
         that the agreement is required to be filed.
Management's Discussion and Analysis of Financial Condition and Results of
Operations of
Ortho
Segment Results, page 209

6.       We note your table of Adjusted EBITDA by segment reconciles to your
non-GAAP
         measure Adjusted EBITDA. This presentation appears to give greater
prominence to the
         non-GAAP measure when compared to Net Loss, which may not be
consistent with Item
         10(e)(1)(i)(A) of Regulation S-K. In addition, your reconciliation
does not appear
         consistent with Item 10(e)(1)(i)(B) of Regulation S-K as you are not
reconciling Total
         Adjusted EBITDA with the most directly comparable financial measure or
measures
         calculated and presented in accordance with GAAP. Please revise your
presentation as
         appropriate, or describe the reasons a change is not necessary. Please
make any
         corresponding changes to fiscal 2020 compared to fiscal 2019.
 Joseph Busky
FirstName  LastNameJoseph Busky
Coronado Topco,  Inc.
Comapany
March      NameCoronado Topco, Inc.
       30, 2022
March3 30, 2022 Page 3
Page
FirstName LastName
7.       Since you have changed the basis by which you measure segment
profitability from
         Management EBITDA to Adjusted EBITDA, please remove your presentation
of fiscal
         2020 and fiscal 2019 non-GAAP Management EBITDA from the filing or
clarify why it
         remains necessary and appropriate disclosure.
The Combinations
Opinion of J.P. Morgan Securities LLC as Financial Advisor to Ortho, page 257

8.       We note your response to comment 15. As it relates to the fairness
opinion of JP Morgan
         Securities, we reissue the comment. Please specifically describe the
"certain operational
         characteristics and/or certain financial metrics" that served as the
selection criteria for the
         publicly traded companies analysis.
Unaudited Forward-Looking Financial Information, page 263

9.       We note your response to comment 16, which we reissue. Please revise
to specifically
         describe the assumptions that were used to produce the projections,
rather than merely list
         the factors that could affect the figures presented.
10.      We note your response to comment 3. As it relates to your amended
disclaimer on page
         264 that "Quidel stockholders are cautioned not to place undue
reliance on the Quidel
         Management Projections," we reissue the comment. Please revise this
statement to
         eliminate any implication that investors are not entitled to rely on
the information included
         in the registration statement.
Comparison of Rights of Holders of Quidel, Ortho, and TopCo, page 316

11.      We note your response to comment 20. Please provide us with a revised
analysis that
         addresses the proposed change, if any, to the authorized capital stock
of TopCo as well as
         the provisions governing Carlyle's board designation rights. In the
alternative, please
         present approval of TopCo   s charter as a separate proposal and
present each provision of
         TopCo   s organizational documents that represents a material change
to the rights of
         Quidel and Ortho shareholders as a separate proposal so that
shareholders have an
         opportunity to express their views separately on material provisions
that will establish
         their substantive rights as shareholders.
 Joseph Busky
Coronado Topco, Inc.
March 30, 2022
Page 4

       You may contact Michael Fay at 202-551-3812 or Kevin Vaughn at
202-551-3494 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Dillon Hagius at 202-551-7967 or Christine Westbrook at 202-551-5019
with any other
questions.



                                                        Sincerely,
FirstName LastNameJoseph Busky
                                                        Division of Corporation
Finance
Comapany NameCoronado Topco, Inc.
                                                        Office of Life Sciences
March 30, 2022 Page 4
cc:       Branden C. Berns, Esq.
FirstName LastName