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                            August 8, 2023

       Julie Zeiler
       Chief Financial Officer
       IRobot Corporation
       8 Crosby Drive
       Bedford , MA 01730

                                                        Re: IRobot Corporation
                                                            Form 10-K for the
fiscal year ended December 31, 2022
                                                            Filed February 14,
2023
                                                            Response Letter
Dated July 10, 2023
                                                            File No. 001-36414

       Dear Julie Zeiler:

              We have reviewed your July 10, 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
       June 12, 2023 letter.

       Form 10-K for the fiscal year ended December 31, 2022

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Key Financial Metrics and Non-GAAP Financial Measures, page 32

   1.                                                   We note your response
to prior comment 1. You indicate you will no longer exclude IP
                                                        litigation expense from
your non-GAAP financial measures in current and future periods;
                                                        however, your proposed
disclosures do not remove the related adjustments from prior
                                                        comparable periods.
Please tell us your consideration of Question 100.02 of the Division
                                                        of Corporation Finance
 s Compliance & Disclosure Interpretations on Non-GAAP
                                                        Financial Measures in
regard to recasting non-GAAP financial measures for prior periods
                                                        and disclosing changes
in the methodology used to calculate them.
 Julie Zeiler
IRobot Corporation
August 8, 2023
Page 2



2.       We note your response to prior comment 2. In order for us to more
fully understand and
         assess the income tax adjustments you recorded to your non-GAAP
financial measures in
         FY 2022 and for each subsequent interim period in FY 2023, please
address the following:
             Demonstrate to us how you calculated the income tax adjustments
for each period.
             Based on the amounts of each income tax adjustment and the amount
of GAAP
             income tax expense, tell us the effective income tax rate related
to your non-GAAP
             financial measures for each period and explain how you concluded
the income tax
             adjustments result in income tax expense commensurate with each
non-GAAP
             financial measure; and
             In regard to the tax valuation allowance, you indicate your
analysis began with a
             determination of whether cumulative losses were present on a
non-GAAP basis and
             you determined you had cumulative three-year income for 2020
through 2022 on a
             non-GAAP basis; however, it appears to us cumulative losses are
present on a non-
             GAAP basis through the quarter ended March 31, 2023. More fully
explain to us
             how this was considered in your analysis and tell us how you
determined that
             potentially recording a tax valuation allowance in different
periods on a GAAP basis
             and a non-GAAP basis is appropriate.




       You may contact Ernest Greene, Staff Accountant at 202-551-3733 or Anne
McConnell,
Staff Accountant at 202-551-3709 with any questions.



FirstName LastNameJulie Zeiler                              Sincerely,
Comapany NameIRobot Corporation
                                                            Division of
Corporation Finance
August 8, 2023 Page 2                                       Office of
Manufacturing
FirstName LastName