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                                                                                                 September 9, 2009  Kevin Tansley Chief Financial Officer IDA Business Park Bray, Co. Wicklow, Ireland
Re: Trinity Biotech plc
 Form 20-F for the Year Ended December 31, 2008  Filed April 7, 2009  File No. 000-22320

Dear Mr. Tansley:

We have reviewed your filing and have the following comments.  In our comments, we
ask you to provide us with information to bett er understand your disclosure.  Where it requests
you to revise disclosure, the information you provid e should show us what the revised disclosure
will look like and identify the annua l or quarterly filing, as applicable, in which you intend to
first include it.  If you do not believe that revi sed disclosure is necessa ry, explain the reason in
your response.  After reviewi ng the information provided, we may raise additional comments
and/or request that you amend your filing.   Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requir ements 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 aspe ct of our review.  Feel free to call us at
the telephone numbers listed at  the end of this letter.

Form 20-F for the fiscal year ended December 31, 2008

Property, Plant and Equipment, page 13

1. Please revise your disclosure in this secti on to include all information required by Item
4(D) of Form 20-F, including the productive capacity of the facilities discussed, the
extent of utilization of the f acilities, how the assets are he ld and the products produced at
each facility.

Kevin Tansley
Trinity Biotech plc September 9, 2009 Page 2  Compensation of Director s and Officers, page 38

2. We note your statement on page 39 that “t he directors were granted 1,665,000 share
options during 2008.”  Item 6(B)(1) of Form  20-F requires disclosure, on an individual
basis, of the title and amount of securities covered by stock options, the exercise price,
the purchase price, if any, and the expirati on date of the options.  Please revise your
disclosure to include the required information.  If disclosure of this information on an
individual basis is not required by your home country of Ireland and this information has
not otherwise been publicly disclosed, please so advise.

3. Please provide the information require d by Item 6(C)(2) of Form 20-F.
 Stock Option Plan, page 40

4. We note the table provided at the bottom of  page 40 disclosing the total options
outstanding as of February 28, 2009.  Item 6(E) of Form 20-F requires disclosure of stock
options granted on an individual basis, rather than in the aggregate.  Please revise your
disclosure accordingly.

Material Contracts, page 49

5. Please revise the disclosure of the company’s material contracts to include a summary of
the terms and conditions of each, as required by Item 10(C) of Form 20-F.

6. Please note that all registrants must provi de the information re quired by Item 16G of
Form 20-F beginning with the annual report that it files for its first fisc al year ended on or
after December 15, 2008.  Please revise your filing to include this information.
 Item 19. Exhibits, page 134

7. Please file all exhibits re quired by Item 19 of Form 20-F, including the company’s
articles of association, bylaws, material c ontracts including related party agreements, and
any other items applicable to the company.

*    *    *    *

Please provide us the information requested wi thin 10 business days or tell us when you
will provide us with a response.  Please furnish a cover letter with your response that keys your
responses to our comments and provide any reques ted information.  Detailed cover letters greatly
facilitate our review.  Please furnish your  letter on EDGAR under the form type label
CORRESP.

 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing in cludes all information re quired under the Securities
Exchange Act of 1934 and that they have provi ded all information investors require for an

Kevin Tansley
Trinity Biotech plc September 9, 2009 Page 3  informed investment decision.  Since the compa ny and its management are in possession of all
facts relating to a company’s disclosure, they are responsible for the acc uracy 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 an d accuracy of the disclo sure 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 comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the sta ff of the Division of Corporati on Finance in our review of your
filing or in response to our comment on your filing.
Please contact Laura Crotty, Staff Attorne y, at (202) 551-3575, Suzanne Hayes, Legal
Branch Chief, at (202) 551-3675 or myself at (202) 551-3715 if you have questions regarding the
processing of your response as well as any que stions regarding comments and related matters.

Sincerely,

Jeffrey P. Riedler Assistant Director