United States securities and exchange commission logo

                             March 2, 2021

       Alan I. Edrick
       Chief Financial Officer
       12525 Chadron Avenue
       Hawthorne, CA 90250

                                                        Re: OSI SYSTEMS INC
                                                            Form 10-K for the
Fiscal Year Ended June 30, 2020
                                                            Filed August 21,
                                                            Form 10-Q for the
Period Ended December 31, 2020
                                                            Filed January 29,
                                                            File No. 000-23125

       Dear Mr. Edrick:

              We have limited our review of your filings to the financial
statements and related
       disclosures 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.

       Form 10-K for the Fiscal Year Ended June 30, 2020

       Note 15. Segment Information, page F-39

   1.                                                   We note the
disaggregated revenue disclosures presented. In light of the significance of
                                                        service revenues to
total revenues and noting that your services are provided by each of
                                                        your segments, please
tell us what consideration was given to also separately
                                                        disclosing product
revenue and service revenue by segment, as well as similar disclosures
                                                        on 'point-in-time'
versus 'over time' revenues. Tell us how you considered the guidance in
                                                        ASC 606-10-50-5 through
7 and ASC 606-10-55-89 through 91 in reaching your
 Alan I. Edrick
March 2, 2021
Page 2
Form 10-Q for the Period Ended December 31, 2020

Note 11. Income Taxes, page 22

2.       We note that you present in this note an effective tax rate excluding
the impact of discrete
         tax items, which appears to be a non-GAAP measure. Please refer to the
guidance in Item
         10(e)(1)(ii)(C) of Regulation S-K which prohibits you from presenting
         measures on the face of or in the notes to your financial statements,
and revise future
         filings to comply. Also, revise your similar disclosures on page 27 in
MD&A to provide
         all disclosures required by Item 10(e) of Regulation S-K.
Results of Operations, page 26

3.       We note your discussion of gross profit only addresses the impact of
increased or
         decreased revenues. Given the significant changes we note in your cost
of goods sold in
         the reported periods, in order to assist an investor's understanding,
please revise future
         filings to also address the impact of changes in your cost of goods
sold on your gross
         profit. Separately quantify and discuss factors responsible for
changes in cost of goods
         sold, including the impact of material variances in components that
offset each other
         within periods. Please consider providing a similar discussion at the
segment level. Refer
         to FR-72.

4.       Please revise the discussion of your results of operations throughout
your future filings to
         not only highlight the reasons for the changes in your income
statement line items but to
         also quantify the impact of each material factor on your results and
to describe the reasons
         underlying each change, including the impact of material variances in
         that offset each other within line items. Also, in your future
discussions avoid terms such
         as "primarily" or "partially offset". Refer to FR-72.
       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.

       You may contact Effie Simpson at (202) 551-3346 or Martin James, Senior
Advisor, at
(202) 551-3671 with any questions.

FirstName LastNameAlan I. Edrick                               Sincerely,
                                                               Division of
Corporation Finance
March 2, 2021 Page 2                                           Office of
FirstName LastName