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Mail Stop 4720
                                                                                                 December 9, 2009  Kevin Tansley Chief Financial Officer Trinity Biotech Plc, One Southern Cross,  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 November 12, 2009 response to our September 9, 2009
comment letter and have the following addi tional comments.  In our comments, we ask
you to provide us with information to be tter understand your di sclosure.  Where it
requests you to revise disclosure, the information you provide should show us what the revised disclosure will look like and identify the annual or quarterly filing, as applicable, in which you intend to first include it.  If you do not believe that revised disclosure is
necessary, explain the reason in your response.  After reviewing 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  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.

General

1. Please confirm that you will include the s ubstance of your responses to our prior
comments 1, 2, 3 and 4 in your Form 20-F for the fiscal year ended December 31,
2009.

Kevin Tansley
Trinity Biotech plc December 9, 2009
Page 2  Material Contracts, page 49

2. We note your response to our prior comment 5 and we reissue the comment.  Please provide draft disclosure to be included in your Form 20-F for the fiscal year ended December 31, 2009 which incl udes a summary of the terms and
conditions of the two material contract s referenced in your response.  Your
disclosure should discuss each party’s rights and obligations under the agreements and the term and termination provisions, in  addition to any other terms material to
an investor’s understanding of the arrangements.
 Item 19. Exhibits, page 134

3. We note your response to our prior comment  7 and advise you that your exhibit
index should also include the service ag reements discussed in response to our
prior comment 3, unless such agreements are not required to  be filed by your
home country or are not otherwise pub licly disclosed, and the two material
contracts discussed in response to our pr ior comment 5.  Also, please file copies
of these agreements to the extent  you have not already done so.

* * *

Please provide us the information request ed within 10 busine ss 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 requested
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 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.

Kevin Tansley
Trinity Biotech plc December 9, 2009 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 comment on your filing.
Please contact Laura Crotty, Staff Atto rney, at (202) 551-3575, Suzanne Hayes,
Legal Branch Chief, at (202) 551-3675 or my self at (202) 551-3715 if you have questions
regarding the processing of your response as well as any questions regarding comments
and related matters.

Sincerely,

Jeffrey P. Riedler Assistant Director