SecProbe.io

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September 29, 2004

Ron Sparks
President and Chief Executive Officer
Medical Device Manufacturing, Inc.
200 West 7th Avenue
Collegeville, Pennsylvania 19426-0992

Re:	Medical Device Manufacturing, Inc.
	Registration Statement on Form S-4
Filed August 30, 2004
	File No. 333-118675

Dear Mr. Sparks:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your document in response to
these comments.  If you disagree, we will consider your explanation
as to why our comment is inapplicable or a revision is unnecessary.
Please be as detailed as necessary in your explanation.  In some of
our comments, we may ask you to provide us with supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

Please understand that the purpose of our review process is to assist
you in your compliance with the applicable disclosure requirements
and to enhance the overall disclosure in your filing.  We look
forward to working with you in these respects.  We welcome any
questions you may have about our comments or on any other aspect of
our review.  Feel free to call us at the telephone numbers listed at
the end of this letter.

General

1. The disclosures throughout the document appear to be presented
from the perspective of UTI Corporation and not from that of the
registrant, Medical Device Manufacturing, Inc. ("MDMI"). You should
revise your disclosure so that you present all required information
about MDMI and, where you also present information about UTI, you
should present that information as the parent of MDMI and not as that
of the registrant. That is, discuss how the information about UTI
impacts MDMI. Why is the information relevant to a debtholder of
MDMI? The financial information should be that of MDMI and not that
of UTI, except where additional financial information of the parent,
UTI, is required. You should clearly separate the discussions for
each. Please revise or advise.

Prospectus Cover Page

2. We note your statement on the cover page that a broker-dealer will
not be deemed to admit that it is an "underwriter" within the meaning
of the Securities Act by acknowledging that it will deliver a
prospectus in connection with any resale of exchange notes received
for its own account pursuant to the exchange offer or by delivering a
prospectus in connection with any such resales.  If you elect to
retain this statement on the cover page, please also disclose on the
cover page that any broker-dealer who holds notes acquired for its
own account as a result of market-making activities or other trading
activities, and who receives exchange notes pursuant to the exchange
offer, may be an "underwriter" within the meaning of the Securities
Act, consistent with our position stated in Shearman & Sterling
(available July 2, 1993).

3. Please disclose on the cover page that both the old notes and the
exchange notes are fully and unconditionally guaranteed by your
domestic subsidiaries, briefly describe the guarantees, and disclose
that the guarantors are each jointly and severally liable.

Cautionary Statement Regarding Forward-Looking Statements - Page ii

4. Section 27A(b)(2)(D) of the Securities Act and Section
21E(b)(2)(D) of the Exchange Act expressly state that the safe harbor
for forward looking statements does not apply to statements made in
connection with a tender offer.  Please delete any references to the
Private Securities Litigation Reform Act.

5. Please relocate this section so that it does not appear before the
Summary and Risk Factors sections.

Industry and Market Data - Page iii

6. Please revise to eliminate your statement in the last sentence of
this paragraph that you "cannot guarantee" the accuracy or
completeness of the industry and market data included in the
prospectus, as investors are entitled rely on statements made in the
prospectus.  If you question the accuracy or completeness of any data
prepared by third parties, you should omit it from the prospectus.

Summary - Page 1

7. Please revise to include a detailed organizational chart
illustrating the ownership structure of MDMI and all of its
subsidiaries in the Summary.  The chart should include the
jurisdiction of incorporation for each entity.

8. We note that much of the disclosure contained in the prospectus
summary, particularly on pages 1 - 4, is identical to the disclosure
contained in other parts on the prospectus, particularly on pages 51
and 54-56.  Your summary should briefly highlight, and not merely
repeat, the key information in your prospectus.  See Item 503(a) and
the instruction thereto.

9. In your revised summary, where applicable, please present a more
balanced description of your business.  For example, if you elect to
retain the lengthy description of your strategy and competitive
advantage in the Summary, please balance those disclosures by
relocating the "Risk Factors" subsection that currently appears on
page 4 so that it appears prior to "The Transactions" subsection in
the Summary and expanding the "Risk Factors" subsection to briefly
identify the most material risks of the exchange offer and an
investment in your company.

10. Revise the first sentence of the Overview subsection on page 1 to
explain "the MedSource Acquisition" and make conforming changes to
the first paragraph of the Business section on page 51.  Please note
that the use of defined terms (including, for example, "Six Sigma"
(page 60), "the Equity Investment" (page 79) and "the Transactions"
(page 80)) should be avoided.  The use of defined terms such as
"Merger Agreement," "Merger Sub," "Term Loan," "New Senior Secured
Credit Facility" and "Revolving Credit Facility" also should be
avoided, as the use of those terms appears unnecessary.  Please
revise the prospectus to limit the use of these and other defined
terms.

11. In the Industry Background subsection, please identify the
"industry sources" referenced in the first paragraph on page 2.
Please also supplementally provide us with copies of the reports or
other documents containing the cited projections and tell us whether
each industry source has consented to your use of those projections
and to the reference to them as the source of that information.

The Transactions - Page 3

12. Please revise to clarify that your reference in this section to
"UTI" is UTI Corporation, a Maryland corporation and your parent, and
not UTI Corporation, a Pennsylvania corporation and your subsidiary.

Other Information - Page 5

13. Your selected financial data indicates that your date of
inception was July 2, 1999, while your disclosures in this section,
as well as your Articles of Incorporation, reflect that you were
incorporated in May 2000.  Please revise to clarify the history of
the development of your business.

Summary of Terms of the Exchange Offer - Page 5

14. Confirm that the exchange offer will be in compliance with Rule
14e-1(a) and open for at least twenty full business days.  Unless the
offer expires at midnight on the twentieth business day following
commencement of the exchange offer, it will be unclear whether the
offer will be open for the full twenty business days.  See Question
and Answer Eight in Exchange Act Release No. 16623 (March 5, 1980).

15. Please revise your disclosures on page 7 to clarify the
consequences of failing to exchange the old notes, including the
potential effect of the exchange offer on the liquidity of the
trading market for the old notes and on the market price of the old
notes.

Summary of Terms of the Exchange Notes - Page 8

16. Under the subheading "Ranking," disclose, if true that the old
notes represent the only currently outstanding senior subordinated
indebtedness of the issuer, and that the exchange notes will be equal
in priority with any old notes that are not exchanged in the exchange
offer.

Summary Historical and Pro Forma Condensed Financial Data - Page 11

17. Please revise to also present cash flows provided by or used in
financing activities.

Risk Factors - Page 14

	Because a significant portion of our net sales . . . - Page 15

18. Please disclose here that Boston Scientific accounted for
approximately 25% of consolidated net sales in 2003.

19. You state that you cannot assure investors that there will not be
a loss or reduction in business from one or more of your major
customers.  Please disclose, as an example of this risk, that you
lost significant customers in 2002, as mentioned in Note 5 to your
financial statements on page F-15.

The unpredictable product cycles . . . - Page 16; Adverse trends or
business conditions - Page 17

20. This risk factor appears to address the same risks to your
business as the risk factor that appears under the heading "[a]dverse
trends or business conditions affecting the medical device industry
or our customers could harm our operating results" on page 17.
Please revise as appropriate.

Quality problems with our processes . . . - Page 18

21. If material, please disclose any of your past failures to meet a
customer`s quality certifications.

Inability to obtain sufficient quantities of raw materials . . . -
Page 19

22. Please disclose any past raw material supply disruptions you have
experienced which have resulted in production delays.

Our international operations are subject to a variety of risks . . .
- Page 19

23. The bullet-point list is generic and does not indicate how these
risks impact your company.  Please revise to use examples that
demonstrate the risk of international operations to your business.

If we become subject to product liability claims . . . - Page 21

24. Please supplementally provide us with details regarding any
product recalls that you have experienced, including those Med Source
recalls referenced here.  We may have additional comments and may
request additional discloser based upon your response.  Also, please
revise this risk factor to state the amount of product liability
coverage that you carry.

Accidents at one of our facilities . . . - Page 22

25. Please disclose any past accidents at your facilities that have
resulted in material production delays.

We depend on our senior management - Page 24

26. Please disclose those members of your senior management with whom
you (or UTI) have entered employment agreements.  In addition, if the
fact that members of your senior management also serve as executives
of UTI and/or your subsidiaries presents a material risk to your
investors, please convert the last sentence of this risk factor into
a separate risk factor that identifies each of your executive
officers who are executives of UTI or any subsidiary and discloses
the other positions held by each such individual.

Risk Relating to the Exchange Notes - Page 25

27. Include a risk factor discussing the risks to investors
associated with the fact that you may redeem the notes at any time on
or after July 15, 2008, and that, prior to July 15, 2007, you may
redeem up to 35% of the notes, as described under the subheading
"Optional Redemption" on pages 88-89.

The Exchange Offer - Page 32

Terms of the Exchange Offer, page 32

28. Revise your disclosure in the fourth paragraph of this section to
clarify that you will return the tendered notes not accepted for
exchange "promptly," not "as promptly as practicable," following the
expiration or termination of the offer.  See Rule 14e-1(c).

	Expiration Date; Extensions; Amendments - Page 32

29. Refer to the first bullet point on page 33.  Supplementally
confirm your understanding that all conditions to the Offer, other
than regulatory approvals, must be satisfied or waived prior to the
Expiration Date, and your intention to pay for or return the notes
promptly following expiration, in keeping with Rule 14e-1(c).

Conditions to the Exchange Offer - Page 36

30. We note your disclosure that you "will not be required to accept
for exchange...any old notes...if at any time before the acceptance
of those old notes for exchange or the exchange of the exchange notes
for those old notes" you determine that the exchange violates
applicable law.  We further note that you have reserved the right to
assert the conditions to the offer "at any time or from time to time
in our sole discretion," which apparently includes assertion of the
conditions after expiration.   Please revise the disclosure to make
clear that all conditions to the offer, other than those involving
governmental approval, must be satisfied or waived before the
expiration of the offer.  We note in this regard that "applicable
law" goes beyond "governmental approval."

Capitalization - Page 38

31. It is not appropriate to include the amount of your cash and cash
equivalents in your total capitalization. Please revise to delete (a)
the line item for cash and cash equivalents and (b) the inclusion of
the amount of your total cash and cash equivalents in the total
amount of your capitalization.

32. If material, please revise to also present your pro forma
capitalization as of June 30, 2004 to reflect the transactions.

Selected Historical Consolidated Financial Data - Page 40

33. We note that you combine your results with your predecessor.
Please tell us and disclose the nature of your predecessor. That is,
who is your predecessor and why? Please also revise your presentation
to separately show your results from those of your predecessor.

34. Your selected financial data indicates that your date of
inception was July 2, 1999, while the "Other Information" section of
the prospectus on page 5, as well as your Articles of Incorporation,
state that you were incorporated in May 2000.  Please revise to
clarify.

Management`s Discussion and Analysis of Financial Condition and
Results of Operations - Page 43

Overview - Page 43

35. Supplementally explain how you selected the nine customers listed
in the second paragraph of this section.

36. On page 15 of the risk factors section of the prospectus, you
present the customer data on a pro-forma basis for the 12 months
ended December 31, 2003, and state that two customers account for
greater that 10% of your net sales, which is inconsistent with your
statement here that only one customer accounted for greater than 10%
of your net sales.  Please revise either here or in the risk factor
to make these statements consistent.

Results of Operations - Page 44

37. Please revise to disclose the actions taken under your "Zero
Defects" quality program and under your "lean" manufacturing cost
reduction program and quantify the known or expected savings, if
material, in connection with each program.

38. We note your presentation of EBITDA on page 44. This presentation
does not appear to comply with Regulation G and Item 10 of Regulation
S-K. Please revise or advise.

39. Please include a discussion of your interest expense and income
taxes, or tell us why the current presentation is appropriate.

40. Tell us why you refer to a loss of customers in the plastic
injection mold operation that led to a significant impairment of
goodwill and intangible assets when discussing your impairment
charges for 2002, but not in your discussion of 2002 and 2001
revenues. How did this loss impact your revenues? Please explain.

41. We note that you have accruals for certain environmental
liabilities. Your disclosure about your environmental contingencies
should be sufficiently specific to enable a reader to understand the
scope of those contingencies affecting you. For example, your
discussion of historical and anticipated environmental expenditures
should, to the extent material, describe separately (a) recurring
costs associated with managing hazardous substances and pollution in
on-going operations, (b) capital expenditures to limit or monitor
hazardous substances or pollutants, (c) mandated expenditures to
remediate previously contaminated sites,