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SEC Comment Letter for TRINITY BIOTECH PLC (TRIB) (CIK 0000888721) (TRIB) — Feb 24, 2010

TRINITY BIOTECH PLC (TRIB) (CIK 0000888721)
Date: Feb. 24, 2010 · CIK: 0000888721 · Accession: 0000000000-10-010490

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Reasoning

File numbers found in text: 000-22320

Referenced dates: January 6, 2010

Date
February 24, 2010
Author
Jeffrey P. Riedler Assistant Director
Form
UPLOAD
Company
TRINITY BIOTECH PLC (TRIB) (CIK 0000888721)

Letter

Via Facsimile and U.S. Mail Mail Stop 4720 February 24, 2010 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 February 16, 2010 response to our January 6, 2010 comment letter and have the following addi tional comment. In our comment, we ask you to provide us with information to better understand your disclosure. Where it requests you to revise disclosure, the information you provide should show us what the revised disclosure will look like and identify the a nnual or quarterly fili ng, as applicable, in which you intend to first include it. If you do not believe th at 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.

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

Item 19. Exhibits, page 134

1. We note your response to comment 1 of our letter dated January 6, 2010 and we reissue the comment. Please file copies of the following two agreements as exhibits: • September 2007 Acquisition Agreement with Cortex Biochem Inc. • October 2007 Acquisition Agreem ent with Sterilab Services UK Once filed, please list th ese agreements in the exhib it index of your next Form 20- F filing, along with the agreements listed in the table provided in your February 16, 2010 response letter.

Kevin Tansley Trinity Biotech plc February 24, 2010 Page 2 * * *

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 comment 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 comment, 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.

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

Show Raw Text
Via Facsimile and U.S. Mail
Mail Stop 4720
                                                                                                 February 24, 2010  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 February 16,  2010 response to our January 6, 2010
comment letter and have the following addi tional comment.  In our comment, we ask you
to provide us with information to better understand your disclosure.  Where it requests
you to revise disclosure, the information you provide should show us what the revised disclosure will look like and identify the a nnual or quarterly fili ng, as applicable, in
which you intend to first include  it.  If you do not believe th at 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.

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

Item 19. Exhibits, page 134

1. We note your response to comment 1 of our letter dated January 6, 2010 and we
reissue the comment.  Please file copies of the following two agreements as
exhibits:
• September 2007 Acquisition Agreement with Cortex Biochem Inc.
• October 2007 Acquisition Agreem ent with Sterilab Services UK
Once filed, please list th ese agreements in the exhib it index of your next Form 20-
F filing, along with the agreements listed in the table provided in your February
16, 2010 response letter.

Kevin Tansley
Trinity Biotech plc February 24, 2010 Page 2
* * *

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 comment 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 comment, 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.

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