<PAGE>
                                       
                     [Letterhead of Intuitive Surgical, Inc.]


                                 June 15, 1998


VIA EDGAR

Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.
Washington, DC  20549

Re:  Intuitive Surgical, Inc.
CIK:  0001035267
Commission File No. 333-50723 Application for Withdrawal

Ladies and Gentlemen:

Pursuant to Rule 477(a) promulgated under the Securities Act of 1933, as 
amended, the undersigned registrant (the "Registrant") hereby applies for an 
order granting the immediate withdrawal of its Registration Statement on Form 
S-1, together with all exhibits and amendments thereto, Commission File No. 
333-50723 (collectively, the "Registration Statement").  The Registration 
Statement was originally filed with the Securities and Exchange Commission 
(the "Commission") on April 22, 1998.

Pursuant to the Registration Statement, the Registrant proposed to register 
certain shares of its Common Stock, $0.001 par value per share (the 
"Shares"), for issuance to the public with a proposed maximum offering price 
of $50,000,000.  The Registrant believes that terms obtainable in the 
marketplace at this time are not sufficiently attractive to warrant 
proceeding with the sale of the Shares.  The offering of the Shares would be 
a discretionary financing for the Registrant, and the Registrant does not 
believe that completing a discretionary financing on unfavorable terms would 
be in the best interests of the Registrant and its stockholders.  No 
securities have been sold under the Registration Statement and all activity 
in pursuit of the offering has been discontinued.

Accordingly, we request an order granting the withdrawal of the Registration 
Statement be issued by the Commission as soon as possible.

If you have any questions regarding the foregoing application for withdrawal, 
please contact Alan C. Mendelson or Patrick A. Pohlen of Cooley Godward LLP, 
legal counsel to the Registrant in connection with the Registration 
Statement, at (650) 843-5000.

                                       Sincerely,                           
                                                                            
                                       Intuitive Surgical, Inc.             
                                                                            
                                       /s/ Lonnie M. Smith                  
                                                                            
                                       Lonnie M. Smith                      
                                       President and Chief Executive Officer


Cc:  Jason P. Wilder -- Nasdaq Stock Market, Inc.
     Alan C. Mendelson, Esq.
     Patrick A. Pohlen, Esq.