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                          April 9, 2021

       James K. Saccaro
       Executive Vice President and Chief Financial Officer
       Baxter International Inc.
       One Baxter Parkway
       Deerfield, Illinois 60015

                                                        Re: Baxter
International Inc.
                                                            Registration
Statement on Form S-4
                                                            Filed April 7, 2021
                                                            File No. 333-255088

       Dear Mr. Saccaro:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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 Tim
Buchmiller at (202) 551-3635 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Life Sciences
       cc:                                              Ari B. Blaut, Esq.