SecProbe.io

September 27, 2010
 Mr. Ronan O’Caoimh
Chief Executive Officer
Trinity Biotech, Plc.
IDA Business Park
Bray, Co. Wicklow, Ireland
Re: Trinity Biotech, Plc.
  Form 20-F for Fiscal Year Ended December 31, 2009
  File No. 000-22320

Dear Mr. O’Caoimh:
 We have limited our review to only your fina ncial statements and related disclosures and
do not intend to expand our review to other por tions of your documents.  In our comments, we
ask you to provide us with information so  we may better underst and your disclosure.
 Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response.  Where a comment requests you to revise disclosu re, the information you provide s hould show us what the revised
disclosure will look like and identify the filing in which you intend to first include it.  If you do
not believe a comment applies to your facts a nd circumstances, please tell us why in your
response.  Please furnish us a letter on EDGAR under the form type label CORRESP that keys
your responses to our comments.
 After reviewing the information provided, we may raise additional comments and/or
request that you amend your filing.  Patents and Licenses, page 10

1. Please disclose the terms of your licensing arrangements and R&D outsourcing to third
parties.  Also, expand your disclosure on pa ge 34 to include estimated payments under
these arrangements.
 Research and Products unde r Development, page 35

2. For each of your research and development projects, please disclose the following
information.

• The costs incurred by you during each period presented and to date on the project;

Mr. Ronan O’Caoimh
Trinity Biotech, Plc. September 27, 2010 Page 2
• The nature, timing and estimated costs to be incurred by you necessary to complete
the project;
• The anticipated completion dates;
• The period in which material net cash inflow s from significant pr ojects are expected
to commence; and
• The risks and uncertainties associated with completing development on schedule and
the consequences to your operations, financia l position and liquidit y, if the project is
not completed on a timely basis.

If you do not maintain any research and develo pment costs by project, disclose that fact
and explain why management does not maintain  and evaluate resear ch and development
costs by project.  Provide other quantitative or  qualitative disclosure that indicates the
amount of the company’s resources being used on each project.  To the extent that you are unable to estimate costs and timing to complete the project, disclose those facts and circumstances indi cating the uncertainties that preclude you from
making a reasonable estimate.
 Notes to the Consolidated Financial Statements

 1.  Basis of Preparation and Significant Accounting Policies

 g) Intangibles, including research and development, page 72

3. Refer to your policy for research and developmen t expenditures.  Please  revise to clarify
how you determine technical feasibility, commer cial viability and cost recovery for a
project as a basis for concluding that the project has moved from a research to a
development phase.  Explain your basis for ut ilizing a 15-year amortization period, when
many of your projects are not protected by speci fic patents.  Also, identify those projects
supporting development costs capitalized in 2009 and 2008 (i.e. $7.8 million and $8.4 million, respectively) and disclose the fact ors supporting your conclusions that these
projects were technically feasible, commercia lly viable and likely to produce future
economic benefits.
u) Tax (current a nd deferred), page 77

4. Please revise your policy regarding the recogn ition of deferred tax as sets to specify, if
true, that you record these assets when it is probable that future ta xable profits will be
available to utilize the associated losses or temporary differences under paragraphs 27
and 34 of IAS 12.  In addition, please revise  Notes 9 and 13 so that the information
provided in these disclosures is consistent.  For example:

Mr. Ronan O’Caoimh
Trinity Biotech, Plc. September 27, 2010 Page 3
• on page 93, clarify the level of uncertainty  prompting less than full recognition of
your deferred tax assets associated with  the various tax losses and temporary
differences; and
• on page 101, clarify why you recognize deferre d tax assets only where there is a
reversing deferred tax liability  in the same jurisdiction re versing in the same period.
Also, clarify whether you consider other sour ces of future taxable profits, and if not,
why not.
 9.  Income Tax Expense (Credit), page 91

5. You disclose a 30.66% item in your rate r econciliation for 2009 rela ted to net operating
losses and temporary differences, for which no deferred tax assets were recognized.
Please revise your disclosure to clarif y what net operating losses and temporary
differences were not recognized and why.  In  addition, please revise your disclosure of
unrecognized deferred tax assets in Note 13 on page 101 to consis tently reflect your
revised disclosure in Note 9, explaining how th is reconciling item impacted the change in
unrecognized deferred tax assets during 2009.

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 the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
  In responding to our comments, please provi de a written 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.

You may contact Frank Wyman, Staff Accountant at (202) 551-3660 or Mark Brunhofer,
Accounting Reviewer at (202) 551-3638, if you have questions regarding these comments.  In
this regard, do not hesitate to contact me, at (202) 551-3679.

Sincerely,

Jim B. Rosenberg
Senior Assistant Chief Accountant