SecProbe.io

November 23, 2010

Mr. Kevin Tansley
Chief Financial 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. Tansley:
 We have reviewed your November 5, 2010 resp onse to our September 27, 2010 letter and
have the following comments.

Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide this information.  Please furnish us a letter
on EDGAR under the form type label CORRESP th at keys your responses to our comments.
 After reviewing the information provided, we may raise additional comments and/or
request that you amend your filing.

Research and Products unde r Development, page 35

1. We acknowledge your response to our previous comm ents two and three.  It appears that the
disclosure of project costs you propose relate s to the projects that you capitalized in the
development phase under paragraph 57 of IAS 38.  Please revise your proposed disclosure to
disclose the significant projects in your research phase and, for each of them, please disclose the following information requested in our previous comment two:
• The costs incurred by you during each period presented and to date on the project;
• 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 costs by pr oject, disclose that fact and explain why
management does not maintain and evaluate re search costs by project.  Provide other

Mr. Kevin Tansley
Trinity Biotech plc November 23, 2010 Page 2
quantitative or qualitative di sclosure that indicates th e 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

Note 1: Basis of Preparation a nd Significant Accounting Policies

g) Intangibles, including research and development, page 72
2. Please revise your proposed disclo sure provided in response to comment three to revise your
listing of development costs capita lized during the periods presented to reconcile these costs
to your total development costs capitalized as indicated in the table on page 98.  In this
regard it appears that the info rmation you provide represents approximately 71% and 75% of
your 2009 and 2008 capitalized development costs.  To the extent you have other
development projects that you di d not identify, please aggregat e the expenditures for those
projects and disclose the criteria you used to specifically identify the projects you did.
u) Tax (current and deferred), page 77
3. We acknowledge your response to our previous comment four and your proposed disclosure
referencing the use of a valuation allowance.   Please explain to us how your use of a
valuation allowance against deferred tax assets is consistent with the guidance in paragraph
24 of IAS 12 to recognize deferred tax assets onl y to the extent it is probable the benefit will
be utilized.
 Note 9: Income Tax Expense / (Credit), page 91
4. We acknowledge your response to our previous comment five.  Please revise your proposed
disclosure regarding deferred tax assets not reco gnized to indicate, that in addition to having
no reversing deferred tax liability in the same ju risdiction, future taxable income in the same
jurisdiction is not probable, consistent with your response to our prev ious comment four.
Otherwise, please advise.
You may contact Mark Brunhof er, Review Accountant, at (202) 551-3638 if you have
questions regarding the comments.  In this rega rd, do not hesitate to contact me at (202) 551-
3679.
Sincerely,

Jim B. Rosenberg Senior Assistant Chief Accountant