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SEC Comment Letter for TRINITY BIOTECH PLC (TRIB) (CIK 0000888721) (TRIB) — Apr 27, 2015

TRINITY BIOTECH PLC (TRIB) (CIK 0000888721)
Date: April 27, 2015 · CIK: 0000888721 · Accession: 0000000000-15-023272

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File numbers found in text: 333-203555

Date
April 27, 2015
Author
/s/ Daniel Greenspan for
Form
UPLOAD
Company
TRINITY BIOTECH PLC (TRIB) (CIK 0000888721)

Letter

April 27, 2015 Via E -mail Ronan O’Caoimh Chairman and Chief Executive Officer Trinity Biotech plc IDA Business Park Bray, Co. Wicklow Ireland

Re: Trinity Biotech plc Registration Statement on Form F-3 Filed April 22, 2015 File No. 333-203555

Dear Mr. O’Caoimh :

This is to advise you that we have not reviewed and will not review your registration statement .

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 Act of 193 3 and all applicable Securities Act rules require. 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 the event you request acceleration of the effective date of the pending regist ration statement , please provide a written statement from the company acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action wit h respect to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in th e filing; and

 the company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for acceleration . We will consider a written request for acceleration of the effective date of the registration statement as confirmation

Ronan O’Caoimh Trinity Biotech plc April 27, 2015 Page 2

of the fact that those requesting acceleration are aware of their respective responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the registered securities .

Please contact Matthew Jones at (202) 551 -3786 or me at (202) 551 -3715 with any other questions.

Sincerely,
/s/ Daniel Greenspan for

Show Raw Text
April 27, 2015

Via E -mail
Ronan O’Caoimh
Chairman and Chief Executive Officer
Trinity Biotech plc
IDA Business Park
Bray, Co. Wicklow
Ireland

Re: Trinity Biotech plc
  Registration Statement on Form F-3
Filed  April 22, 2015
  File No.  333-203555

Dear Mr. O’Caoimh :

This is to advise you that we have not  reviewed and will not review your registration
statement .

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 Act of 193 3 and
all applicable Securities  Act rules require.   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 the event you request acceleration of the effective date of the pending regist ration
statement , please provide  a written statement from the company acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action wit h respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in th e filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation

Ronan O’Caoimh
Trinity Biotech plc
April 27, 2015
Page 2

 of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the registered securities .

Please contact Matthew Jones  at (202) 551 -3786 or me at (202) 551 -3715  with any other
questions.

Sincerely,

 /s/ Daniel Greenspan for

Jeffrey P. Riedler
Assistant Director

cc: Alan J. Bernstein, Esq.
Carter Ledyard & Milburn LLP
2 Wall Street
New York, New York 10005