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Correspondence

November 11, 2009

Laura Crotty

Staff Attorney

United States Securities and Exchange Commission

100 First Street N.E.

Washington D.C. 20549

    Re:

    Trinity Biotech Plc

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

    Filed April 7, 2009

    File No. 000-22320

Dear Ms. Crotty,

Following your letter to us dated September 9, 2009 and our subsequent correspondence filed on
October 16, 2009, please find our replies to the queries raised in your aforementioned letter.
Where the information from the requests raised in your letter requires us to revise our disclosure,
we have included the proposed revised disclosure in our response below. We intend revising these
disclosures in our Form 20-F to be submitted for the financial year ending 31 December, 2009,
subject to this being to your satisfaction.

Query 1

Property, Plant and Equipment

“Please revise your disclosure in this section to include all information required by Item 4(D) of
Form 20-F, including the productive capacity of the facilities discussed, the extent of utilization
of the facilities, how the assets are held and the products produced at each facility.”

Response

In relation to the information required by Item 4 (D) of Form 20-F and in addition to the
information provided on page 13 of our Form 20-F we would like to further add that:

    (1)

    At present we have sufficient productive capacity to cover demand for our product
range. We continue to review our level of capacity in the context of future revenue
forecasts. In the event that these forecasts indicate capacity constraints, we will either
obtain new facilities or expand our existing facilities.

    (2)

    We do not currently have any plans to expand or materially improve our facilities.

    (3)

    In relation to products produced at our facilities — these are as follows:

    Bray, Ireland — this is the principal Haemostasis manufacturing site within the Group.
Clinical Chemistry, Point of Care/HIV and Immunoflourescence products are also manufactured
at this site.

    Lemgo, Germany — this facility is responsible for the production of our Haemostasis
instrumentation and the associated plastic consumables for use with these instruments.

    Jamestown, New York — this site specializes in the production of Microtitre Plate EIA
products for infectious diseases and auto-immunity.

    Carlsbad, California — this facility specializes in the development and manufacture of
products utilizing Western Blot technology. Our Lyme suite of products is manufactured at
this facility.

    Kansas City, Missouri — this site is responsible for the manufacture of the Group’s A1c
range of products.

    (4)

    We are fully in compliance with all environmental legislation applicable in each
jurisdiction in which we operate.

Query 2

Compensation of Directors and Officers

“We note your statement on page 39 that “the directors were granted 1,665,000 share options during
2008.” Item 6(B)(1) of Form 20-F requires disclosure, on an individual basis, of the title and
amount of securities covered by stock options, the exercise price, the purchase price, if any, and
the expiration date of the options. Please revise your disclosure to include the required
information. If disclosure of this information on an individual basis is not required by your home
country of Ireland and this information has not otherwise been publicly disclosed, please so
advise.”

Response

The granting of stock options to directors and executive officers in 2008 in the amount of
1,665,000 options was comprised as set out below.

    Number of Options

    Exercise Price of

    Date of Option

    Director/Executive Officer

    Granted

    Options Granted

    Grant*

    Brendan Farrell

    250,000 A shares

    $4.30 per ADR

    18 March 2008

    Rory Nealon

    200,000 A shares

    $4.30 per ADR

    18 March 2008

    Ronan O’Caoimh

    175,000 A shares

    $4.30 per ADR

    18 March 2008

    Kevin Tansley

    150,000 A shares

    $4.30 per ADR

    18 March 2008

    Brendan Farrell

    300,000 A shares

    $2.95 per ADR

    16 September 2008

    Rory Nealon

    240,000 A shares

    $2.95 per ADR

    16 September 2008

    Ronan O’Caoimh

    200,000 A shares

    $2.95 per ADR

    16 September 2008

    Kevin Tansley

    150,000 A shares

    $2.95 per ADR

    16 September 2008

*All options issued are subject to a 7 year life from date of grant.

Query 3

Compensation of Directors and Officers

“Please provide the information required by Item 6(C)(2) of Form 20-F.”

Response

The Company has entered into service contracts with its Executive Directors and Officers. These
contracts contain certain termination provisions which are summarised below.

Under the terms of his service contract Ronan O’Caoimh, Chairman and Chief Executive, is entitled
to 12 months salary and benefits in the event of termination by the Company. Where termination
arises within 12 months of a change in control of the Company, Mr. O’Caoimh is entitled to 24
months salary and benefits.

Under the terms of his service contract Rory Nealon, Chief Operations Officer, is entitled to 12
months salary and benefits in the event of termination by the Company. Where termination arises
within 12 months of a change in control of the Company, Mr. Nealon is entitled to 18 months salary
and benefits.

Under the terms of his service contract Kevin Tansley, Chief Financial Officer, is entitled to 12
months salary and benefits in the event of termination by the Company. Where termination arises
within 12 months of a change in control of the Company, Mr. Tansley is entitled to 18 months salary
and benefits.

Query 4

Stock Option Plan

“We note the table provided at the bottom of page 40 disclosing the total options outstanding as of
February 28, 2009. Item 6(E) of Form 20-F requires disclosure of stock options granted on an
individual basis, rather than in the aggregate. Please revise your disclosure accordingly.”

Response

As of February 28, 2009, 4,114,085 of the options outstanding were held by directors and officers
of Trinity Biotech, comprised as follows:

    Number of

    Options

    Director/Officer

    (A Shares)

    Exercise Price

    Expiration Date of Options

    Ronan O’Caoimh

    133,334

    $6.00 Per ADR

    23 December 2009

    133,334

    $7.00 Per ADR

    04 January 2010

    167,000

    $3.92 Per ADR

    04 October 2009

    450,000

    $10.24 Per ADR

    26 August 2011

    250,000

    $6.68 Per ADR

    02 November 2012

    350,000

    $8.36 Per ADR

    13 December 2013

    175,000

    $4.30 Per ADR

    18 March 2015

    200,000

    $2.95 Per ADR

    16 September 2015

    Rory Nealon

    100,000

    $3.92 Per ADR

    04 October 2009

    175,000

    $10.24 Per ADR

    26 August 2011

    100,000

    $6.68 Per ADR

    02 November 2012

    150,000

    $8.36 Per ADR

    13 December 2013

    200,000

    $4.30 Per ADR

    18 March 2015

    240,000

    $2.95 Per ADR

    16 September 2015

    Denis Burger

    50,000

    $3.92 Per ADR

    04 October 2009

    60,000

    $10.24 Per ADR

    26 August 2011

    25,000

    $6.68 Per ADR

    02 November 2012

    25,000

    $8.36 Per ADR

    13 December 2013

    Jim Walsh

    95,000

    $7.00 Per ADR

    04 January 2010

    166,667

    $3.92 Per ADR

    04 October 2009

    168,750

    $10.24 Per ADR

    26 August 2011

    50,000

    $6.68 Per ADR

    02 November 2012

    25,000

    $8.36 Per ADR

    13 December 2013

    Peter Coyne

    50,000

    $3.92 Per ADR

    04 October 2009

    60,000

    $10.24 Per ADR

    26 August 2011

    25,000

    $6.68 Per ADR

    02 November 2012

    25,000

    $8.36 Per ADR

    13 December 2013

    Kevin Tansley

    20,000

    $5.52 Per ADR

    28 January 2010

    20,000

    $11.16 Per ADR

    19 May 2011

    20,000

    $6.36 Per ADR

    16 August 2012

    30,000

    $7.12 Per ADR

    26 July 2013

    75,000

    $8.96 Per ADR

    07 March 2014

    150,000

    $4.30 Per ADR

    18 March 2015

    150,000

    $2.95 Per ADR

    16 September 2015

Query 5

Material Contracts

“Please revise the disclosure of the company’s material contracts to include a summary of the terms
and conditions of each, as required by Item 10(C) of Form 20-F.”

Response

We propose to change the wording under the heading Material Contracts in the 20F on page 49 to:

Other than contracts entered into in the ordinary course of business, the following represents the
material contracts entered into by the Group, for the two years immediately preceding the
publication of this Form 20-F:

Acquisition of the immuno-technology business of Cortex Biochem Inc

In September 2007, the Group acquired the immuno-technology business of Cortex Biochem Inc
(“Cortex”) for a total consideration of US$2,925,000, consisting of cash consideration of
US$2,887,000 and acquisition expenses of US$38,000.

Acquisition of certain components of the distribution business of Sterilab Services UK

In October 2007, the Group acquired certain components of the distribution business of Sterilab
Services UK (“Sterilab”), a distributor of Infectious Diseases products, for a total consideration
of US$1,489,000, consisting of cash consideration of US$1,480,000 and acquisition expenses of
US$9,000.

Query 6

Material Contracts

“Please note that all registrants must provide the information required by Item 16G of Form 20-F
beginning with the annual report that it files for its first fiscal year ended on or after December
15, 2008. Please revise your filing to include this information.”

Response

As Trinity Biotech is a foreign private issuer, it is not required to comply with all of the
corporate governance requirements set forth in NASDAQ Rule 4350 as they apply to U.S. domestic
companies. The Group’s corporate governance measures differ in the following significant ways. The
Audit Committee of the Group currently consists of two members — while U.S. domestic companies
listed on NASDAQ are required to have three members on their audit committee. In addition, the
Group has not appointed an independent nominations committee or adopted a board resolution
addressing the nominations process. Finally, the Group’s Executive Chairman serves on the Group’s
Remuneration Committee with two non-executive independent directors, while U.S. domestic companies
are required to have executive officer compensation determined by a remuneration committee
comprised solely of independent directors or a majority of the independent directors.

The above disclosure is already included in our 2008 Form 20-F in Paragraph 2 on Page 40.

Query 7

Exhibits

“Please file all exhibits required by Item 19 of Form 20-F, including the company’s articles of
association, bylaws, material contracts including related party agreements, and any other items
applicable to the company.”

Response

The table below is a list of the exhibits which have already been filed with the SEC in connection
with a prior filing of a registration statement or periodic report. We propose to include the list
of exhibits in our 2009 Form 20-F, subject to your agreement.

    Exhibit

    No.

    Description of Exhibit

    Incorporated by Reference To

    1.1

    Memorandum and Articles of
Association of Trinity Biotech plc.

    Filed as an Exhibit 1 to
the Form 20-F filed with
the U.S. Securities and
Exchange Commission on
March 31, 2006.

    1.2

    Form of Deposit Agreement dated as
of October 21, 1992, as amended and
restated, among Trinity Biotech
plc, The Bank of New York as
Depositary, and all Owners and
holders from time to time of
American Depositary Receipts issued
thereunder.

    Filed as Exhibit 1 to the
Form F-6 filed with the
U.S. Securities and
Exchange Commission on
January 15, 2004.

    4.1

    Trinity Biotech plc Employee Share
Option Plan 2003.

    Filed as Exhibit 4 to the
Form S-8 Registration
Statement filed with the
U.S. Securities and
Exchange Commission on
April 28, 2005.

    4.3

    Sale and Purchase Agreement among
bioMerieux, Inc., Trinity Biotech
Manufacturing Limited and Trinity
Biotech plc, as guarantor, dated
May 24, 2006, as amended by
Amendment Number One dated June 22,
2006.

    Filed as Items 2 and 3 to
the Form 6-K filed with the
U.S. Securities and
Exchange Commission on June
30, 2006.

    4.4

    Lease agreement dated as of October
18, 2004 between Ronan O’Caoimh and
Jim Walsh with Trinity Biotech
Manufacturing Limited in respect of
office premises in Bray, Co
Wicklow, Ireland.

    Filed as an Exhibit 4b.1 to
the Form 20-F filed with
the U.S. Securities and
Exchange Commission on
March 31, 2006.

    4.5

    Lease agreement dated as of
November 26, 2004 between Ronan
O’Caoimh, Jonathon O’Connell and
Jim Walsh with Trinity Biotech plc
in respect of warehouse premises in
Bray, Co Wicklow, Ireland.

    Filed as an Exhibit 4b.2 to
the Form 20-F filed with
the U.S. Securities and
Exchange Commission on
March 31, 2006.

    8.1

    Subsidiaries of Trinity Biotech plc.

    Filed as Item 18, note 31
to the consolidated
financial statements to the
Form 20-F filed on April 7,
2009.

In the event that you have any queries please contact me at +353 1 2769800.

Yours sincerely,

/s/ Kevin Tansley

Kevin Tansley

Chief Financial Officer

Trinity Biotech plc.