SecProbe.io

Via Facsimile and U.S. Mail Mail Stop 6010                                                                                                   August 24, 2007   Mr. Ronan O’Caoimh Director and Chief Executive Officer Trinity Biotech Plc. IDA Business Park Bray, Co. Wicklow, Ireland
Re: Trinity Biotech Plc.
Form 20-F for the Fiscal Year Ended December 31, 2006 Filed May 8, 2007
 File No. 000-22320

Dear Mr. O’Caoimh:
We have reviewed your filing and have the following comments.  We have
limited our review to only your financial stat ements and related disclosures and do not
intend to expand our review to  other portions of your docum ent.  In our comments, we
ask you to provide us with information so we may better understa nd your disclosure.
After reviewing this information, we may raise additional comments.    Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our  comments or on any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 Item 18.  Finical Statements, page 54

Notes to the Consolidated Financial Statements
 1.  Basis of Preparation and Significant Accounting Policies

g)  Intangibles, Including Research and Development (Other Than Goodwill)

 Research and development, page 63

1. Please provide us a list of the activities (completed and not completed) and their
capitalized amounts that comprise the $18,240,000 of “Development costs” at
December 31, 2006 as indicated in Note 11. For each activity (completed and not

Mr. Ronan O’Caoimh
Trinity Biotech Plc. August 24, 2007 Page 2
 completed), tell us the date capitalized, th e nature of the activ ity and address how
you met each of the criteria in paragr aph 57 of IAS 38.  For activities not
completed at December 31, 2006, also tell us the nature, dollar amount and timing of efforts remaining to be completed.
 26.  Business Combinations

2006 Acquisitions, page 96

2. To assist us in evaluating, for US GAAP purposes, your accounting for the
haemostis product line acquired from bioMerieux as a business combination
under SFAS 141 rather than as an asset acq uisition, please provide us an analysis
under paragraph six of EITF 98-3 to de monstrate how the haemostasis product
line constitutes a business.   Your analysis should include a list of inputs,
processes and outputs that we re transferred in order to continue normal operations
and sustain a revenue stream.  If any el ement of inputs, processes and outputs as
listed under EITF 98-3 is missing, provide us a discussion as to how the missing
element is not required in continuing normal operations.

*    *    *    *

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please furnish a letter that  keys your responses to our
comments and provide the requested information.  Detailed letters gr eatly facilitate our
review.  Please furnish your letter on EDGAR under the form type label CORRESP.
  We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our co mments, please provide, in your letter, a
statement from the company acknowledging that:
• the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

Mr. Ronan O’Caoimh
Trinity Biotech Plc. August 24, 2007 Page 3

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
You may contact Kei Ino, Staff Accountan t, at (202) 551-3659 or Jim Atkinson,
Accounting Branch Chief, at (202) 551- 3674 if you have questions regarding the
comments.  In this regard, do not hes itate to contact me, at (202) 551-3679.

Sincerely,

Jim B. Rosenberg Senior Assistant Chief Accountant