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CORRESP
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CORRESP

    Jim Rosenberg

Senior Assistant Chief Accountant

    December 20, 2010

    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, 2009

File No. 000-22320

Dear Jim,

In reference to your letter dated November 23, 2010, I set out responses to the queries raised in
relation to our Form 20-F for fiscal year ended December 31, 2009. Where the information
requested 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, 2010, subject to this being to your
satisfaction.

Query 1

Research and Products under Development (page 35)

“Please revise your proposed disclosure to disclose significant projects in your research phase and
for each of them, please disclose the following information:

    •

    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 inflows from significant projects are expected to
commence; and

    •

    The risks and uncertainties associated with completing development on schedule and the
consequences to your operations, financial position and liquidity, if the project is not
completed on a timely basis.”

Page 1

Response

I confirm that there were no significant development projects in their research phase during 2009.
The following sentence will be added to the section headed Research and Products under Development
on page 35.

“There were no significant development projects in their research phase during 2009.”

Query 2

Basis of preparation and Significant Accounting Policies

g) Intangibles, including research and development, page 72

“Please revise your proposed disclosure provided to comment to revise your listing of development
costs capitalized during the periods presented to reconcile these costs to your total development
costs capitalized as indicated in the table on page 98. To the extent you have other development
projects that you did not identify, please aggregate the expenditures for those projects and
disclose the criteria you used to identify the projects you did.”

Response

Goodwill and Intangible Assets (page 98)

In the intangible fixed asset note (Note 12), we intend to provide more information in relation to
development costs. The following is the additional disclosure:

“The following represents the costs incurred during each period presented for each of the principal
development projects:

    2009

    2008

    Product Name

    US$’000

    US$’000

    Destiny Max coagulation instrument

    3,234

    4,508

    Tristat point of care instrument

    1,072

    823

    HPLC Instrument for Haemoglobin A1c testing

    1,023

    672

    Coagulation assays and intermediates

    1,010

    380

    Lyme assays

    629

    495

    Unigold Recombigen HIV Rapid enhancement

    456

    603

    Bordetella Pertussis Western Blot test

    156

    0

    Trinblot Scanner

    72

    297

    Other projects with spend less than $150,000

    193

    648

    Total capitalized development costs

    7,845

    8,426

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Query 3

Tax (current and deferred)

“Please explain to us how your use of a valuation allowance against deferred tax assets is
consistent with the guidance in paragraph 23 of IAS 12 to recognize deferred tax assets only to the
extent it is probable the benefit will be utilized.”

Response

In this context the use of the term “valuation allowance” might be confusing as valuation
allowances are used to restrict deferred tax assets under US GAAP but not under IFRS. To ensure
that users of the financial statements understand that they are prepared under IFRS, we propose to
remove the term valuation allowance.

The amended disclosure in note 13 Deferred Tax Assets and Liabilities is as follows:

“The deferred tax asset in 2009 is due mainly to deductible temporary differences and the
elimination of unrealised intercompany inventory profit. The deferred tax asset increased in 2009
principally due to a decrease in unrecognised deferred tax assets. The accounting policy for
deferred tax is to calculate the deferred tax asset that is deemed recoverable, considering all
sources for future taxable profits. However when there is a reversing deferred tax liability in
that jurisdiction that reverses in the same period, the deferred tax asset is restricted so that it
equals the reversing deferred tax liability.”

In our previous reply of November 5, 2010, we presented a table showing the unrecognized deferred
tax assets by jurisdiction. Again to avoid any confusion, we propose to replace the term “valuation
allowance” with the term unrecognized deferred tax asset.

Page 3

Query 4

Income Tax Expense (Credit) (pages 91)

“Please revise your proposed disclosure regarding deferred tax assets not recognized to indicate,
that in addition to having no reversing deferred tax liability in the same jurisdiction, future
taxable income in the same jurisdiction is not probable, consistent with your response to our
previous comment four. Otherwise, please advise.”

Response

In the Income tax expense disclosure note (note 9), we will revise the disclosure to include a
statement regarding future taxable income in the jurisdictions. The revised wording is:

“The effect of current year net operating losses and temporary differences for which no deferred
tax asset was recognized is analyzed further in the table below (see also note 13). No deferred tax
asset was recognized because there was no reversing deferred tax liability in the same jurisdiction
reversing in the same period and no future taxable income in the same jurisdiction.

In the event that you have any queries please contact me at +35312769864.

Yours sincerely,

/s/ Kevin Tansley

Kevin Tansley

Chief Financial Officer

Trinity Biotech plc

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