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                             April 11, 2023

       Glenn Boehnlein
       Vice President, Chief Financial Officer
       STRYKER CORP
       2825 Airview Boulevard
       Kalamazoo, Michigan 49002

                                                        Re: STRYKER CORP
                                                            Form 10-K for
Fiscal Year December 31, 2022
                                                            Filed February 10,
2023
                                                            Form 8-K Filed
January 31, 2023
                                                            File No. 001-13149

       Dear Glenn Boehnlein:

              We have reviewed your March 30, 2023 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
       March 30, 2023 letter.

       Form 10-K for Fiscal Year December 31, 2022

       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Critical Accounting Policies and Estimates
       Acquisitions, Goodwill and Intangible Assets, and Long-Lived Assets,
page 18

   1.                                                   Your response to
comment 7 indicates that given recent central bank-led interest rate hikes
                                                        and the overall
macroeconomic environment, you elected to perform a quantitative
                                                        impairment test for
Spine at your annual testing date of October 31, 2022. Please tell us
                                                        why these two factors
did not result in you performing quantitative assessments for any of
                                                        your other reporting
units as of October 31, 2022. Address the need to expand your
                                                        disclosures to address
this apparent inconsistency.
 Glenn Boehnlein
FirstName
STRYKERLastNameGlenn   Boehnlein
             CORP
Comapany
April       NameSTRYKER CORP
       11, 2023
April 211, 2023 Page 2
Page
FirstName LastName
2.       Your draft disclosure provided as part of your response to comment 7
states that the
         impairment charge was    significantly affected by the discount rate."
Please expand this
         disclosure to clarify the extent to which revenue, gross profit and
operating income
         margin falling short of internal expectations impacted the impairment
test and the
         resulting material impairment charge. To the extent that operational
issues and trends
         impacted the impairment test, provide a discussion of the previous
expectations, the
         degree to which your historical results fell short of the 2021
expectations, and the degree
         to which your historical results impact the 2022 impairment test.
Finally, we note that
         with the 2021 impairment test, the Spine reporting unit had an implied
fair value that
         exceeded the carrying amount by 51%. Please include this information
in your draft
         disclosure to allow investors to better understand the discussion of
the factors that
         materially impacted the fair value of the Spine reporting unit
subsequent to the 2021
         impairment test.
Notes to Consolidated Financial Statements, page 27

3.       We note your response to comment 8 regarding the costs you have
referred to as
         restructuring activities, specifically your conclusion that these
costs are not within the
         scope of ASC 420 as the costs do not meet the FASB Codification
definition of
         restructuring. Please provide us with a more comprehensive explanation
of the activities
         generating these costs for the last three fiscal years and an analysis
of the guidance in
         ASC 420-10-15-3 and 15-4. In this regard, we note that ASC 420-10-15-4
states, in part,
            [a]n exit activity includes but is not limited to a restructuring
.. Also address liabilities
         and costs related to exit activities associated with business
combinations in accordance
         with ASC 420-10-15-3.e. In this regard, we note that you also
recognized workforce
         reduction and termination of sales relationships in your other
acquisition and integration-
         related charges adjustment.
Note 15 - Asset Impairments, page 38

4.       Your response to comment 8 indicates that you recognized long-lived
asset write-offs and
         impairment charges of $96 million, $203 million, and $184 million for
2022, 2021, and
         2020, respectively. However, your cash flow statement reflects
impairment charges of
         $54 million, $264 million, and $215 million for these same periods and
the discussion in
         Note 15 only addresses impairments of $47 million in 2022 and $105
million in 2021.
         Please address the apparent discrepancies related to your 2021
impairment charges and
         tell us why Note 15 does not discuss the entire $264 million
impairment referenced in
         your cash flows or the asset impairments recognized for 2020. Also,
address the need to
         provide the disclosures required by ASC 820-10-50-2 for your
nonrecurring fair value
         measurements.
Form 8-K Filed January 31, 2023
Exhibit 99.1, page A-1

5.       We note your response to comment 10, including the draft disclosure
you intend to
 Glenn Boehnlein
STRYKER CORP
April 11, 2023
Page 3
         provide when presenting free cash flow excluding recall payments.
Please help us
         understand how you determined that free cash flow excluding recall
payments is a
         performance measure rather than a liquidity measure. In this regard,
we note the measure
         is reconciled from cash provided by operating activities; includes
cash in the title; the
         adjustments are cash-based rather than accrual-based; and your
non-GAAP conversion
         rate uses this measure as the numerator.
Definitive Proxy Statement on Schedule 14A

Appendix A, page A-1

6.       We note your presentation of free cash flow excluding recall payments.
Please tell us how
         you determined that this presentation, which is outside of your
compensation discussion
         and analysis section, is consistent with the requirements in Item
10(e)(1)(ii)(a) of
         Regulation S-K. See our related comment above.

       You may contact Tracey Houser at 202-551-3736 or Jeanne Baker at
202-551-3691, if
you have questions regarding comments on the financial statements and related
matters.



                                                             Sincerely,
FirstName LastNameGlenn Boehnlein
                                                             Division of
Corporation Finance
Comapany NameSTRYKER CORP
                                                             Office of
Industrial Applications and
April 11, 2023 Page 3                                        Services
FirstName LastName