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[Hogan & Hartson L.L.P. Letterhead]

January 6,
2005

EDGAR and Overnight Courier

United States Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549-0305

Mail Stop 04-05

Attn:

Donald C. Hunt

David Ritenour

Heather Tress

Kate Tillan

Re:Medical Device Manufacturing, Inc. Amendment No. 3 to Registration Statement on Form S-4 Filed August 30, 2004 and
amended on October 25, 2004 and December 7, 2004

File No. 333-118675

Ladies and Gentlemen:

        On
behalf of Medical Device Manufacturing, Inc., a Colorado corporation ("MDMI"), this letter responds to the comments 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 MDMI, dated December 20, 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 filed by MDMI on
October 25, 2004 and Amendment No. 2 thereto filed by MDMI on December 7, 2004 (as amended, the "Registration Statement"). Filed herewith is Amendment No. 3 ("Amendment
No. 3") to the Registration Statement, which has been marked to show changes from Amendment No. 2.

        MDMI's
responses to the Staff's comments 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. 3. The responses provided herein are based on discussions with, and information
furnished by, MDMI and its advisors. Once the Staff has reviewed MDMI's responses to the comments contained in the comment letter, MDMI would welcome the opportunity to discuss any additional
questions the Staff may have to facilitate expedient resolution of any remaining issues.

General

        1.     Comment: Please file your December 2, 2004 letter to the staff on EDGAR as correspondence.

        Response:    MDMI complied with this comment on December 27, 2004.

The Transactions—Page 35

        2.     Comment: See prior comment 4. Please revise to quantify each of the transactions, including the merger, the repurchase of
Class C redeemable preferred stock, the payment of dividends to Class A and separately Class C preferred shareholders, and the issuance and sale of the old notes. Also clarify the
type of consideration paid, where applicable.

        Response:    MDMI has complied with this comment on pages 13 and P-1.

Contractual Obligations and Commitments—Page 60

        3.     Comment: See prior comments 9 and 11. Please reconcile the amounts presented in the tables to the amounts presented and
disclosed in your financial statements and notes. Under paragraph 16(b) of SFAS 13, you should disclose aggregate future minimum rental payments under operating leases. Why does

 the amount of other long-term obligations in the December 31, 2003 table of $9,621,000 not agree to the amount of other long-term liabilities as of December 31,
2003 shown on page F-3 of $13,314,000? You should reflect all other long-term liabilities as reflected on your balance sheet under GAAP. See Item 303(a)(5) of
Regulation S-K. Also tell us why the table reflects the obligation as current (i.e., due in less than one year) while the balance sheet reflects the amount as
long-term.

        Response:    MDMI has complied with this comment by revising note 16 on page F-36 to reflect the aggregate
amount of minimum rental commitments under operating lease obligations due after 5 years and the aggregate obligations for all future periods presented. As a result of the revisions to
note 16, the operating lease obligations as of December 31, 2003 reflected in the table on page 60 now matches the amount reflected in note 16.

        Total
other long-term liabilities on the consolidated balance sheet of MDMI as of December 31, 2003 were as follows:

Environmental liabilities

$
4,036

Deferred income taxes

1,917

Employee compensation and benefits

2,971

Accrued interest expense

4,390

Total other long-term liabilities

$
13,314

        MDMI
has revised the December 31 table of contractual commitments on page 60 to include deferred income taxes, accrued employee compensation and benefits and accrued
interest expense in other long-term obligations. MDMI has removed the $9,621,000 obligation for the Venusa earn-out from the table of contractual commitments since that
obligation is not long-term. The Venusa earn-out obligation is now disclosed on page 59 under the caption Liquidity and Capital Resources.

        MDMI
has not included accrued environmental liabilities since the accrual is not a contractual obligation. The employee compensation and benefits includes deferred incentive
compensation, severance and pension accruals. MDMI has discussed the potential impact on MDMI from the settlement of environmental liabilities on page 59 under the caption Liquidity and Capital
Resources. As revised, the tables reflect all long-term obligations required to be disclosed pursuant to Regulation S-K Item 303(a)(5).

        4.     Comment: See prior comment 9. Due to the fact that your December 31, 2003 table excludes purchase obligations that
you are not able to calculate and since your contractual obligations and commitments have changed materially due to the Transactions, please revise the table as of September 30, 2004 to present
all of the specified categories of Item 303(a)(5) of Regulation S-K, including the amount of your other long-term liabilities as reflected on your balance sheet under
GAAP in the table.

        Response:    Total other long-term liabilities on the consolidated balance sheet of MDMI as of September 30,
2004 were as follows (in thousands):

Environmental liabilities

$
8,748

Deferred income taxes

4,245

Employee compensation and benefits

5,496

Restructuring accrual—future lease payments

11,148

Total other long-term liabilities

$
29,637

        MDMI
has revised the September 30 table of contractual commitments on page 61 to include deferred income taxes and accrued employee compensation and benefits in other
long-term obligations.

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        MDMI
has not included in the table accrued environmental liabilities since the accrual is not a contractual obligation. The employee compensation and benefits includes deferred incentive
compensation, severance, phantom stock obligations and pension accruals. Additionally, the $11,148,000 of future lease payments that has been accrued as a restructuring cost is included in the
$23,066,000 operating lease obligations disclosed in the contractual commitments table on page 61.

Security Ownership of Certain Beneficial Owners and Management—Page 60

        5.     Comment: We note your response to comment 14. Please revise your disclosures in footnote (4) to the beneficial
ownership table to clarify the relationship between DLJ Merchant Banking Partners III, L.P., DLJ Merchant Banking III, L.P., DLJ Merchant Banking III, Inc., Credit Suisse First Boston LLC, and
the "related funds" identified in that footnote, rather than just stating that DLJ Merchant Banking Partners III, L.P. and the related funds "form a part of Credit Suisse First Boston's
Alternative Capital Division." Please also disclose, if true, that all investments for DLJ Merchant Banking Partners III, L.P. and the related funds are made by an investment committee. In addition,
please disclose the general nature, composition and structure of that investment committee, including the method used to determine membership of the committee.

        Response:    MDMI has complied with this comment on pages 6 and 90.

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

Consolidated Statements of Cash Flow—Page F-6

        6.     Comment: It appears that you reflect the sale of the pushed down redeemable and convertible preferred stock of parent
company in 2003 as a capital infusion from parent. This representation is not consistent with treating these shares as being pushed down in your financial statements. Please revise or
advise.

        Response:    The sale of the Series C 8% Redeemable Preferred Stock of Parent Company has been pushed down from Accellent
to MDMI. The cash flows from financing activities on the consolidated statement of cash flows on page F-6, and the supplemental guarantor statements of cash flows on
pages F-42 and F-63 have been revised to reflect separately the push down of redeemable and convertible preferred stock of the parent company from the amount of capital
contributed to permanent equity.

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

        7.     Comment: See prior comment 16. We note that you have elected, between two different balance sheet classification methods,
to make no accounting entries based upon the initial measurement of compensation, instead of reporting the entire amount of measured compensation as deferred compensation. As such, please revise to
highlight your accounting method selection in your accounting policies footnote.

        Response:    MDMI has complied with this comment on page F-12.

        8.     Comment: We note your response to our prior comment 19 and require additional information. Your response from the
February 14, 2001 letter to comment 81 also contains similar information that only one subsidiary has had customer relationships for 20 years or more. Please supplementally provide a
detailed explanation of your analysis of the estimate of useful lives of your customer base as requested in our prior comment. It does not appear as though all customers have a relationship lasting
20 years or more and as such, the proper matching of revenues and expenses is not achieved. With only one subsidiary having such lengthy relationships, please explain why this was chosen for
all customer bases acquired. Please also note that you should use the average expected life and not the maximum life of a single or a few customers.

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        Response:    The customer base intangible was identified in connection with three separate acquisitions during fiscal 2000. The
total amount allocated to this intangible from all three acquisitions was $22.1 million. Of this total amount, $14.6 million relates to the June 1, 2000 acquisition of UTI
Corporation, a Pennsylvania Corporation ("UTI-PA"). UTI-PA has been in operation since the 1940s and was incorporated in 1969. Due to changes in the company's business systems
over the years, MDMI cannot provide an exact documented date of when specific customer relationships began. However, MDMI has re-confirmed that with respect to UTI-PA's
five largest customers in fiscal 2000, most relationships have been in existence for longer than 20 years. UTI-PA's customer relationships with each of GE and Metem are greater than
35 years old. The customer relationships with each of Smith & Nephew and Abbott are greater than 20 years old. The customer relationship with Johnson & Johnson is greater
than 15 years old. Based on this information and consultation with valuation experts, which recommended a customer attrition rate of 5% per year and a useful life of 20 years, management
determined that a life of 20 years was appropriate for this intangible.

        The
next largest portion of the customer base intangible, $4.2 million, was identified and recorded in connection with MDMI's acquisition of Noble-Met on
January 11, 2000. Noble-Met had, and continues to have, a very strong position with customers due to their reputation for customer service. Noble-Met began operations in
1989 and has experienced minimal customer attrition throughout its existence. Its major customers were large well established multinational medical device manufacturers such as Boston Scientific and
Johnson & Johnson. Based on the stability of its customer base and consultation with valuation experts, management determined that a 20-year life was appropriate for this
intangible.

        The
remaining portion of the customer base intangible was $3.3 million recorded in connection with MDMI's acquisition of American Technical Molding, Inc. ("ATM") on
December 22, 2000. ATM was incorporated in 1988, and at the time of its acquisition had 22 customers who accounted for approximately 90% of 1999 revenues. Based on consultation with valuation
experts management determined that a 20-year life was reasonable notwithstanding ATM's subsequent unforeseen loss in 2002 of two major customers. Please see the response to comment 11 for
a further discussion of the assumptions used to value the ATM customer base intangible. Please see the response to comment 12 for a further discussion of the cause for the ATM customer base intangible
impairment in fiscal 2002.

        9.     Comment: See prior comment 20. For actual returns processed in 2001, 2002, 2003 and 2004, please tell us the total amount
processed and then segregate the returns by the year to which the return relates. Provide an analysis using this data of your reserve requirements vs. your actual reserve balance as of
December 31, 2001, 2002, and 2003, and September 30, 2004. Tell us why this information is not included in Schedule II.

        Response:    By way of additional background, actual sales returns processed by MDMI are recorded at the gross sales value, with
a corresponding credit to cost of sales for the value of the inventory returned. At the end of a period MDMI estimates the required sales return reserve. MDMI records sales return reserves based on
the net value of the sale less the value of the inventory to be returned with a corresponding debit to sales.

        Actual
sales returns processed by MDMI for fiscal years 2001, 2002, 2003 and the first nine months of fiscal 2004 were $2,846,010, $2,860,184, $3,543,526 and $4,983,970,
respectively. Sales returns processed as a percentage of gross revenue for fiscal years 2001, 2002, 2003 and the first nine months of fiscal 2004 were 2.1%, 2.1%, 2.0% and 2.3%,
respectively.

        MDMI
has evaluated actual returns processed in the subsequent fiscal year to identify the actual amount of returns processed that relate to the revenue reported in the prior periods. The
amount of

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returns
at sales value that relate to the prior periods, the respective inventory value, and net reserve value are as follows:

        a.     Actual
returns processed subsequent to September 30, 2004 relating to revenue recorded in the first nine months of fiscal 2004, $724,633 sales value,
$514,235 inventory value, resulting in a net reserve requirement of $210,398;

        b.     Actual
returns processed in fiscal 2004 relating to fiscal 2003 revenue, $1,091,065 sales value, $741,619 inventory value, resulting in a net reserve requirement of
$349,446;

        c.     Estimated
returns processed in fiscal 2003 relating to fiscal 2002 revenue, $259,697 sales value, $180,406 inventory value, resulting in a net reserve requirement of
$79,291;

        d.     Estimated
returns processed in fiscal 2002 relating to fiscal 2001 revenue, $148,176 sales value, $105,524 inventory value, resulting in a net reserve requirement of
$42,652.

        Beginning
in the second quarter of fiscal 2003, MDMI implemented a process to track returns monthly, matching each return to the month of actual sale. MDMI has used this actual return
data to determine the amount of net return reserves to record, and to respond to this comment. For the years ended December 31, 2001 and 2002, MDMI estimated the portion of returns
processed in fiscal 2003 and 2002 which relate to the prior years based on an examination of credit memos and analytical procedures.

        As
noted above, MDMI records sales return reserves based on the net value of the sale less the value of the inventory to be returned. Inventory returned to MDMI generally require