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December 2, 2004

FACSIMILE TRANSMITTAL

Please deliver the following pages to:

Name:

Heather Tress

Kate Tillan

Organization:

United States Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549-0305

Mail Stop 04-05

Telecopier Number: (202) 942-9585

Total Number of Pages, Including Cover Sheet: 10

From:

Stewart A. Fisher, Chief Financial Officer

Thomas F. Lemker, Vice President Finance

Timothy S. Mathews, Corporate Controller

Re:Medical Device Manufacturing, Inc. Registration Statement on Form S-4

Filed August 30, 2004 and amended on October 25, 2004

File No. 333-118675

        This letter includes preliminary responses to comments number 15 and 17 of the staff (the "Staff") of the Securities and Exchange Commission (the "Commission")
set forth in a letter (the "comment letter") to Ron Sparks, President and Chief Executive Officer of Medical Device Manufacturing, Inc. ("MDMI"), dated November 8, 2004, regarding the
Registration Statement on Form S-4 (Commission File No. 333-118675) filed by MDMI on August 30, 2004, as amended by Amendment No. 1 thereto
("Amendment No. 1") filed by MDMI on October 25, 2004 (as amended, the "Registration Statement").

        MDMI's
preliminary responses to the Staff comments 15 and 17 are set forth below and are numbered to correspond to the numbering of the Staff's comments in the comment letter.

        Unless
otherwise indicated, all references to page numbers in the responses below refer to page numbers in Amendment No. 2 to the Registration Statement, which is
yet to be filed. We are providing these preliminary responses to facilitate a discussion of these two comments with the Staff on Friday, December 3, 2004, at 10:00 a.m. EST. We intend to
review the response for these two comments with the Staff, to assure that we have appropriately addressed each comment and provided sufficient information in our response.

        We
have arranged a conference call number of (800) 910-2399, passcode 285366 for the call.

        MDMI
also advises the Staff that its parent corporation changed its name from UTI Corporation to Accellent, Inc. on November 18, 2004. MDMI has reflected the name change in
the preliminary responses to Staff comments 15 and 17 below.

Medical Device Manufacturing, Inc. Financial Statements—Page F-2

        15.   Comment: Please refer to our prior comment 1. As previously requested, please provide disclosures from the perspective of
Medical Device Manufacturing, Inc. ("MDMI"). For example, do the debt covenants on page F-19 apply to UTI or MDMI, or both? Is it MDMI's pension plan or UTI's? What about the profit
sharing and SERP? Is MDMI the lessee or UTI for the operating leases discussed on page F-33? If UTI,

 why are the amounts and disclosures included in MDMI's financial statements? With respect to your stock-based compensation and Note 8, please revise to provide your disclosure from the
perspective of MDMI, the registrant. Were the options granted for common shares of MDMI or UTI? Are 100% of the options granted by UTI pushed down to MDMI? Why? Please explain. Does MDMI have a stock
option plan?

        Response:    The term "Company" is defined in the first paragraph of note 1 to MDMI's audited consolidated financial
statements as "Medical Device Manufacturing, Inc. and its wholly owned subsidiaries". Accellent, therefore, is excluded from that term. And, it is the Company, as defined, that is subject to
the debt covenants disclosed in note 6 to MDMI's audited consolidated financial statements. MDMI has updated note 6 on page F-18 to clarify that the covenants and
restrictions apply only to the Company, and not to Accellent. There were no covenants or restrictions on the Accellent senior notes for which MDMI was required to comply.

        The
pension plan is the Company's obligation, and not Accellent's. MDMI has revised note 7 to MDMI's audited consolidated financial statements on page F-20 to clarify
that the German pension plan is an obligation of the Company. Accellent, as MDMI's holding company with minimal activity, incurs no direct wage or benefit expenses.

        The
SERP and profit sharing plans have been described in note 7 as plans of the Company. These plans are not plans of Accellent.

        As
disclosed in note 16 to MDMI's audited consolidated financial statements on page F-33, the lease obligations are obligations of the Company, and not of
Accellent. Accellent does not lease any facilities or assets.

        MDMI
has revised the stock option disclosures in note 1 on page F-12 and note 8 to MDMI's audited consolidated financial statements on page
F-23 to clarify that all options granted were Accellent stock options, that all grants by Accellent were to employees of MDMI, and that MDMI does not maintain a separate stock option plan.
MDMI has reflected stock-based compensation for grants of Accellent stock options to MDMI employees in accordance with paragraph 14 of FIN 44. Also, please see MDMI's response to comment 16.

Note 1. Summary of Significant Accounting Policies—Page F-7

        17.   Comment: Please refer to our prior comments 89, 114, 126, and 127. Please respond to the following comments:

        a)    Provide us with a detailed response addressing why you believe that it is appropriate to push down UTI's debt and related interest expense and UTI's equity
to MDMI.
Specifically address the interpretive response to Question 3 of SAB Topic 5J and how it applies to your specific facts and circumstances. Also, since Question 3 and the interpretive response discuss
debt, you should explain in detail why you believe it is appropriate to also push down equity. What is the basis for this conclusion?

         b)    Also discuss why your method of pushing down the equity is appropriate. That is, we note that you reflect the UTI redeemable and convertible preferred stock
as a separate
line item in MDMI's balance sheet, but you reflect UTI's other preferred stock and common stock as lump sum entries within additional paid-in capital.

         c)     Tell us whether all of the debt and equity of UTI was pushed down to MDMI. If not, please explain why the debt or equity was not pushed down.

         d)    What assets, liabilities, and equity, or income and expenses of UTI have not been pushed down to MDMI and why?

         e)     You should revise your disclosures to clarify the reasons for your accounting treatment. Include a discussion of MDMI's rights and obligations with
respect to the pushed
down debt of UTI. It

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 should be clear from your disclosure what amounts/transactions of UTI you have included in MDMI's financial statements, how you measure and reflect those amounts/transactions, and why.

         f)     Please revise to provide all of the applicable disclosures required by SAB Topic 1:B.

        g)     Please note that upon resolving this issue, we may have additional comments regarding the disclosures in your filing to properly reflect the outcome.

        Response:    Accellent has raised capital by issuing debt and common and preferred equity. The preferred equity issued consisted
of convertible preferred stock, redeemable preferred stock, and redeemable and convertible preferred stock. Accellent has advanced the proceeds from these debt and equity issuances to MDMI to fund
acquisitions. The table below lists the debt and equity issuances of Accellent, and matches each capital raising issuance to the related MDMI subsidiary acquisition:

Accellent Security

Date Issued

Amount of Proceeds

(in thousands)

Use of Proceeds

Voting common stock

July 1999

$
2

Acquisition of G&D Inc. d/b/a Star Guide, a subsidiary of MDMI ("Star Guide")

Class A-1 5% Convertible Preferred Stock

July 1999

$

9,500

Acquisition of Star Guide

Non-voting common stock issued pursuant to warrants sold in July 1999

July 1999

$

1,000

Acquisition of Star Guide

Class B-1 Redeemable Convertible Preferred Stock

July 1999

$

30

Acquisition of Star Guide

Class A-2 5% Convertible Preferred Stock

January 2000 & March 2001

$

13,500

Acquisition of Noble-Met, Ltd., a subsidiary of MDMI, and payment of contingent consideration for the Noble-Met acquisition

Class A-3 5% Convertible Preferred Stock

May 2000

$

500

Acquisition of MER

Class A-4 5% Convertible Preferred Stock

May 2000

$

55,000

Acquisition of UTI Corporation, a Pennsylvania corporation and a subsidiary of MDMI ("UTI Pennsylvania")

Class AA Convertible Preferred Stock

May 2000

$

6,870

Acquisition of UTI Pennsylvania

Class B-2 Redeemable Convertible Preferred Stock

May 2000

$

10

Acquisition of UTI Pennsylvania

Senior notes due June 2008

June 2000

$

17,206

Acquisition of UTI Pennsylvania

Class A-5 5% Convertible Preferred Stock

December 2000

$

15,928

Acquisition of ATM, a subsidiary of MDMI, and contingent consideration payment for acquisition of Noble-Met

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Class A-6 5% Convertible Preferred Stock

December 2001

$

3,086

Contingent consideration payments relating to the acquisition of ATM

Class C 8% Redeemable Preferred Stock

February 2003

$

12,554

Acquisition of Venusa, a subsidiary of MDMI

Class AB Warrants

February 2003

$

6,196

Warrants issued with Class C Redeemable Preferred Stock in connection with the acquisition of Venusa

Class A-7 5% Convertible Preferred Stock

May 2004

$

27,292

Contingent consideration payment relating to the acquisition of Venusa.

Class A-8 5% Convertible Preferred Stock

June 2004

$

88,047

Acquisition of MedSource Technologies, Inc.; payment of dividends on Class A-1 through Class A-7 Convertible Preferred Stock; redemption of Class C 8% Redeemable Preferred Stock

        The
senior notes, which comprise all debt of Accellent, have been pushed down to MDMI based on the guidance in Question 3 of SAB Topic 5J. According to this guidance, debt of the parent
should be reflected on the financial statements included in the registration statement of the subsidiary if the debt relates to the parent's acquisition of the subsidiary and the subsidiary:
(1) will assume the debt presently or in a planned transaction in the future; (2) the proceeds of the debt or equity offering of the subsidiary will be used to retire all or part of the
parent's debt; or (3) the subsidiary guarantees or pledges its assets as collateral for the parent's debt.

        The
proceeds from the issuance of the senior notes of Accellent were advanced to MDMI to acquire UTI Pennsylvania. MDMI used these funds along with capital contributions from Accellent
to acquire UTI Pennsylvania, MDMI's subsidiary. Additionally, the proceeds of the senior subordinated note offering of MDMI, to which this Registration Statement relates, were used to retire all of
the senior notes of Accellent. Based on these facts and the guidance of Question 3 of SAB Topic 5J, the senior notes of Accellent should be pushed down to and reflected on the financial statements of
MDMI.

        Accellent
has also raised capital in the form of Class B-1 and B-2 Convertible and Redeemable Preferred Stock and Class C Redeemable Preferred
Stock. As of December 31, 2003, MDMI has (in thousands) $12,593 of redeemable and convertible preferred stock of parent company on its consolidated balance sheet. This amount is comprised of:
$12,553 of Class C Redeemable Preferred Stock, with the balance of $40 representing the Class B-1 and B-2 Redeemable and Convertible Preferred Stock. These
securities are not treated as permanent equity in the separate financial statements of Accellent in accordance with Regulation S-X Item 5-02(28) and ASR 268. Since these
securities are not permanent equity, MDMI has applied the principles of Question 3 of SAB Topic 5J to determine if push down accounting is appropriate. The proceeds from the Class C Redeemable
Preferred Stock offering were used by MDMI to fund the acquisition of Venusa as described in the table above. Additionally, the proceeds of the senior subordinated note offering of MDMI, to which this
Registration Statement relates, were used to redeem the Class C Redeemable Preferred Stock of Accellent. Based on these facts and the guidance of Question 3 of SAB Topic 5J, the Class C

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Redeemable
Preferred Stock of Accellent should be pushed down to and reflected on the financial statements of MDMI outside of permanent equity.

        Accellent
contributed the proceeds from the sale of its common stock and convertible preferred stock to MDMI. MDMI is not obligated to repay these funds to Accellent. Therefore, these
amounts are treated by MDMI as contributions to capital and reflected as additional paid in capital on the financial statements of MDMI. MDMI has revised its disclosure throughout the prospectus to
clarify that it has treated these advances from Accellent as capital contributions to MDMI and not as a push-down of Accellent's equity.

        All
of the expenses incurred by Accellent for the periods presented were as follows (in thousands):

Fiscal Year

Ended 2001

Fiscal Year

Ended 2002

Fiscal Year

Ended 2003

Nine Months Ended

September 30, 2004

Stock-based compensation

$
(109
)
$
(222
)
$
(191
)
$
(127
)

Initial public offering costs

(2,328
)

—

—

—

Interest expense

(4,732
)

(5,166
)

(5,823
)

(6,670
)

Beneficial conversion of convertible preferred stock

(1,762
)

Accretive dividend on the Class C Redeemable Preferred Stock

(6,196
)

        The
stock-based compensation, initial public offering costs and interest expense noted above were reflected in the statement of operations of MDMI based on the following:

        a.     The
stock-based compensation expense of Accellent relates entirely to options granted to employees of MDMI. MDMI has recorded this same amount of compensation in its
statement of operations in accordance with APB 25. Please see MDMI's response to comment 16.

        b.     Accellent
incurred costs for an initial public offering of its stock. These costs were expensed by Accellent since the offering was not completed. The proceeds from this
stock offering were intended to be used to reduce debt of MDMI, or for general corporate purposes of MDMI. Therefore, in accordance with Question 1 of SAB Topic 1B, MDMI has reflected all of these
costs in its statement of operations as they were incurred by Accellent on behalf of MDMI.

        c.     In
accordance with Question 3 of SAB Topic 5J, we have pushed down interest expense, which includes debt issuance costs, from Accellent to MDMI on debt pushed down from
Accellent to MDMI.

        MDMI
did not reflect the beneficial conversion feature of the Class A-6 5% Convertible Preferred Stock, or the accretive dividend on the Class C 8% Redeemable
Preferred Stock in the statement of operations of MDMI. In accordance with SFAS No. 128, earnings per share is computed by dividing net income available to common shareholders by the weighted
average number of shares outstanding for each period presented. Net income is reduced by dividends and other distributions on preferred stock to arrive at net income available to common shareholders.
Since MDMI common stock is not publicly traded, MDMI is not required to present either net income available to common shareholders or earnings per share. As a result, the beneficial conversion feature
and dividends on preferred stock of Accellent have not been reflected on or allocated to the statement of operations for MDMI. Accellent did contribute the net proceeds of the
Class A-6 5% Convertible Preferred Stock to the capital of MDMI, which amounted to $3.1 million ($4.9 million total value of the securities issued, less the beneficial
conversion feature of $1.8 million, for net proceeds of $3.1 million). MDMI has reflected the $3.1 million received from Accellent as a capital contribution during the 2001 fiscal
year. Accellent also

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contributed
to MDMI the net proceeds of $86.9 million from Accellent equity transa