SecProbe.io

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                                                           February 27, 2026

John Gillard
Chief Executive Officer
Trinity Biotech PLC
IDA Business Park
Bray, County Wicklow,
A98 H5C8, Ireland

        Re: Trinity Biotech PLC
            Registration Statement on Form F-1
            Filed February 25, 2026
            File No. 333-293717
Dear John Gillard:

       This is to advise you that we have not reviewed and will not review your
registration
statement.

        Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

       Please contact Doris Stacey Gama at 202-551-3188 with any questions.

                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Life
Sciences
cc:    Mary W. Brown, Esq.
</TEXT>
</DOCUMENT>

CORRESP
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    TRINITY BIOTECH PLC

    February 27, 2026

    VIA EDGAR

    U.S. Securities and Exchange Commission

    Division of Corporation Finance

    Office of Life Sciences

    100 F Street, NE

    Washington, D.C. 20549

            Attention:

            Doris Stacey Gama

            Re: Trinity Biotech plc

              Registration Statement on Form F-1

              File No. 333- 293717

    To Ms. Gama:

    The undersigned, on behalf of Trinity Biotech plc (“Trinity”), issuer of the securities covered by the
      above-referenced Registration Statement, hereby respectfully requests that the above-referenced Registration Statement be declared effective by the Securities and Exchange Commission at 4:00 p.m. Eastern Time on Tuesday,  March 3, 2026, or as soon
      thereafter as possible.

    Please contact Steven Glusband (212-238-8605, glusband@clm.com) or Mary Brown (212-238-8765, mbrown@clm.com) of
      Carter Ledyard & Milburn LLP with any questions you may have concerning this request.

                Very truly yours,

                /s/ Paul Murphy

                Paul Murphy

                Chief Financial Officer

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                                                           January 20, 2026

John Gillard
Chief Executive Officer
Trinity Biotech plc
IDA Business Park
Bray, County Wicklow,
A98 H5C8,
Ireland

        Re: Trinity Biotech plc
            Registration Statement on Form F-1
            Filed January 15, 2026
            File No. 333-292753
Dear John Gillard:

       This is to advise you that we have not reviewed and will not review your
registration
statement.

        Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

       Please contact Tim Buchmiller at 202-551-3635 with any questions.

                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Life
Sciences
cc:    Mary Brown, Esq.
</TEXT>
</DOCUMENT>

CORRESP
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    TRINITY BIOTECH PLC

    January 21, 2026

    VIA EDGAR

    U.S. Securities and Exchange Commission

    Division of Corporation Finance

    Office of Life Sciences

    100 F Street, NE

    Washington, D.C. 20549

            Attention: Tim Buchmiller

              Re: Trinity Biotech plc

                Registration Statement on Form F-1

                File No. 333- 292753

    To Mr. Buchmiller:

    The undersigned, on behalf of Trinity Biotech plc (“Trinity”), issuer of the securities covered by the
      above-referenced Registration Statement, hereby respectfully requests that the above-referenced Registration Statement be declared effective by the Securities and Exchange Commission at 4:00 p.m. Eastern Time on Friday, January 23, 2026, or as soon
      thereafter as possible.

    Please contact Steven Glusband (212-238-8605, glusband@clm.com) or Mary Brown (212-238-8765, mbrown@clm.com) of
      Carter Ledyard & Milburn LLP with any questions you may have concerning this request.

                Very truly yours,

                /s/ Paul Murphy

                Paul Murphy

                Chief Financial Officer

CORRESP
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 TRINITY BIOTECH PLC

 March 26, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission
 Division of Corporation Finance
 Office of Life Sciences
 100 F Street, NE
 Washington, D.C. 20549

 Attention:

 Daniel Crawford

 Re: Trinity Biotech plc
 Registration Statement on Form F-3
 File No. 333-   286020

 To Mr. Crawford:

 The undersigned, on behalf of Trinity Biotech plc (“Trinity”), issuer of the securities covered by the
 above-referenced Registration Statement, hereby respectfully requests that the above-referenced Registration Statement be declared effective by the Securities and Exchange Commission at 4:00 p.m. Eastern Time on Friday, March 28, 2025, or as soon
 thereafter as possible.

 Please contact Steven Glusband (212-238-8605, glusband@clm.com) or Mary Brown (212-238-8765, mbrown@clm.com) of
 Carter Ledyard & Milburn LLP with any questions you may have concerning this request.

 Very truly yours,

 /s/ Louise Tallon
 Louise Tallon
 Chief Financial Officer

March 26, 2025
John Gillard
Chief Executive Officer and Director
Trinity Biotech plc
IDA Business Park
Bray, County Wicklow,
A98 H5C8
Ireland
Re:Trinity Biotech plc
Registration Statement on Form F-3
Filed March 21, 2025
File No. 333-286020
Dear John Gillard:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Daniel Crawford at 202-551-7767 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Mary Brown, Esq.

CORRESP
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    TRINITY BIOTECH PLC

    November 29, 2024

    VIA EDGAR

    U.S. Securities and Exchange Commission

    Division of Corporation Finance

    Office of Life Sciences

    100 F Street, NE

    Washington, D.C. 20549

            Attention:

            Chris Edwards

            Re: Trinity Biotech plc

              Registration Statement on Form F-3

              File No. 333- 283273

    To Mr. Edwards:

    The undersigned, on behalf of Trinity Biotech plc (“Trinity”), issuer of the securities covered by the
      above-referenced Registration Statement, hereby respectfully requests that the above-referenced Registration Statement be declared effective by the Securities and Exchange Commission at 4:00 p.m. Eastern Time on Monday, December 2, 2024, or as soon
      thereafter as possible.

    Please contact Steven Glusband (212-238-8605, glusband@clm.com) or Mary Brown (212-238-8765, mbrown@clm.com) of
      Carter Ledyard & Milburn LLP with any questions you may have concerning this request.

                Very truly yours,

                /s/ Louise Tallon

                Louise Tallon

                Chief Financial Officer

    .

November 21, 2024
John Gillard
Chief Executive Officer
Trinity Biotech plc
IDA Business Park
Bray, County Wicklow
Ireland
Re:Trinity Biotech plc
Registration Statement on Form F-3
Filed November 15, 2024
File No. 333-283273
Dear John Gillard:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Chris Edwards at 202-551-6761 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Mary Brown, Esq.

CORRESP
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    TRINITY BIOTECH PLC

    June 26, 2024

    VIA EDGAR

    U.S. Securities and Exchange Commission

    Division of Corporation Finance

    Office of Life Sciences

    100 F Street, NE

    Washington, D.C. 20549

            Attention:

            Chris Edwards

            Re: Trinity Biotech plc

              Registration Statement on Form F-3

                File No. 333-280391

    To Mr. Edwards:

    The undersigned, on behalf of Trinity Biotech plc (“Trinity”), issuer of the securities covered by the above-referenced Registration Statement, hereby respectfully requests that
      the above-referenced Registration Statement be declared effective by the Securities and Exchange Commission at 4:00 p.m. Eastern Time on Friday, June 28, 2024, or as soon thereafter as possible.

    Please contact Steven Glusband (212-238-8605, glusband@clm.com) or Mary Brown (212-238-8765, mbrown@clm.com) of Carter Ledyard & Milburn LLP with any questions you may have
      concerning this request.

                Very truly yours,

                /s/ Des Fitzgerald

                Des Fitzgerald

                Interim Chief Financial Officer

    .

United States securities and exchange commission logo
June 25, 2024
John Gillard
Chief Executive Officer
Trinity Biotech plc
IDA Business Park
Bray, County Wicklow
A98 H5C8
Ireland
Re:Trinity Biotech plc
Registration Statement on Form F-3
Filed June 21, 2024
File No. 333-280391
Dear John Gillard:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Chris Edwards at 202-551-6761 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Mary Brown, Esq.

CORRESP
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    TRINITY BIOTECH PLC

    May 3, 2024

    VIA EDGAR

    U.S. Securities and Exchange Commission

    Division of Corporation Finance

    Office of Life Sciences

    100 F Street, NE

    Washington, D.C. 20549

            Attention:

            Lauren Hamill

            Re: Trinity Biotech plc

              Registration Statement on Form F-3

                File No. 333-279017

    To Ms. Hamill:

    The undersigned, on behalf of Trinity Biotech plc (“Trinity”), issuer of the securities covered by the above-referenced Registration Statement, hereby respectfully requests that
      the above-referenced Registration Statement be declared effective by the Securities and Exchange Commission at 9:00 am. Eastern Time on Tuesday, May 7, 2024, or as soon thereafter as possible.

    Please contact Steven Glusband (212-238-8605, glusband@clm.com) or Mary Brown (212-238-8765, mbrown@clm.com) of Carter Ledyard & Milburn LLP with any questions you may have
      concerning this request.

                Very truly yours,

                /s/ John Gillard

                John Gillard

                Chief Executive Officer

United States securities and exchange commission logo
May 2, 2024
John Gillard
Chief Executive Officer
Trinity Biotech plc
IDA Business Park
Bray, Co. Wicklow
Ireland
Re:Trinity Biotech plc
Registration Statement on Form F-3
Filed April 30, 2024
File No. 333-279017
Dear John Gillard:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Lauren Hamill at 303-844-1008 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Mary Brown

CORRESP
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    September 12, 2022

    VIA EDGAR

    Securities and Exchange Commission

    Division of Corporation Finance

    Office of Life Sciences

    100 F Street, N.E.

    Washington, D.C. 20549

    Attn: Christine Westbrook

              Re:

                Trinity Biotech Plc

                  Registration Statement on Form F-3

                File No. 333-267160

    Ms. Westbrook:

    The undersigned, on behalf of Trinity Biotech Plc (“Trinity”), issuer of the securities covered by the above-referenced Registration Statement, hereby respectfully requests that
      the above-referenced Registration Statement be declared effective by the Securities and Exchange Commission at 4:00 p.m. Washington, D.C. time on Wednesday, September 14, 2022, or as soon thereafter as possible.

    Management of Trinity is aware of its responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the disposition of the securities
      covered by the above-referenced Registration Statement.

    Thank you very much for your courtesy in this matter.

                Very truly yours,

                /s/ John Gillard

                John Gillard

                Chief Financial Officer

                            Trinity Biotech

              T +353 1 276 9800

              Trinity Biotech PLC Limited

                            One Southern Cross

              F +353 1 276 9888

              Registered in Ireland. Registration number 183476

                            IDA Business Park

              info@trinitybiotech.com

              Directors: R O’Caoimh (CEO), Seon Kyu Jeon, Dr. J Walsh,

                            Bray, Co Wicklow

              www.trinitybiotech.com

              J Gillard, A Kekedjian, M Sung Soo Kim

                            Ireland

United States securities and exchange commission logo
September 6, 2022
Ronan O'Caoimh
Chief Executive Officer
Trinity Biotech plc
IDA Business Park
Bray, Co. Wicklow, Ireland
Re:Trinity Biotech plc
Registration Statement on Form F-3
Filed August 30, 2022
File No. 333-267160
Dear Mr. O'Caoimh:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Christine Westbrook at 202-551-5019 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Mary W. Brown, Esq.

CORRESP
1
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      May 23, 2022

      VIA EDGAR

      Securities and Exchange Commission

      Division of Corporation Finance

      Office of Life Sciences

      100 F Street, N.E.

      Washington, D.C. 20549

      Attn:  Jordan Nimitz, Esq.

                Re:

                  Trinity Biotech Plc

                    Registration Statement on Form F-3

                     File No. 333-264992

      Dear Mr. Edwards:

      The undersigned, on behalf of Trinity Biotech Plc (“Trinity”), issuer of the securities covered by the above-referenced Registration Statement, hereby respectfully requests that
        the above-referenced Registration Statement be declared effective by the Securities and Exchange Commission at 4:00 p.m. Washington, D.C. time on Wednesday, May 25, 2022, or as soon thereafter as possible.

      Management of Trinity is aware of its responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the disposition of the
        securities covered by the above-referenced Registration Statement.

      Thank you very much for your courtesy in this matter.

                  Very truly yours,

                  John Gillard

                  Chief Financial Officer

                  Trinity Biotech

                  T +353 1 276 9800

                  Trinity Biotech PLC Limited

                  One Southern Cross

                  F +353 1 276 9888

                  Registered in Ireland. Registration number 183476

                  IDA Business Park

                  info@trinitybiotech.com

                  Directors: Ronan O’Caoimh (CEO),

                  Bray, Co Wicklow

                  www.trinitybiotech.com

                  Sun-Q Jeon (Chairman), John Gillard, Dr.
                    Jim Walsh,

                  Ireland

                  Michael Sung Soo Kim, Aris Kekedjian

United States securities and exchange commission logo
May 23, 2022
Ronan O’Caoimh
Chief Executive Officer
Trinity Biotech PLC
IDA Business Park
Bray, Co. Wicklow
Ireland
Re:TRINITY BIOTECH PLC
Registration Statement on Form F-3
Filed May 16, 2022
File No. 333-264992
Dear Mr. O’Caoimh:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Jordan Nimitz at 202-551-5831 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Steven J. Glusband, Esq.

CORRESP
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      [LETTERHEAD OF TRINITY BIOTECH Plc]

      July 13, 2020

      VIA EDGAR

      Securities and Exchange Commission

      100 F Street, N.E.

      Washington, D.C. 20549

      Attn:  Charles Edwards, Esq.

                Re:

                  Trinity Biotech Plc

                    Registration Statement on Form F-3

                  File No. 333-239701

      Dear Mr. Edwards:

      The undersigned, on behalf of Trinity Biotech Plc (“Trinity”), issuer of the securities covered by the
        above-referenced Registration Statement, hereby respectfully requests that the above-referenced Registration Statement be declared effective by the Securities and Exchange Commission at 4:00 p.m. Washington, D.C. time on Wednesday, July 15, 2020,
        or as soon thereafter as possible.

      Management of Trinity is aware of its responsibilities under the Securities Act of 1933 and the Securities Exchange
        Act of 1934 as they relate to the disposition of the securities covered by the above-referenced Registration Statement.

      Thank you very much for your courtesy in this matter.

              Very truly yours,

              /s/ Kevin Tansley

              Kevin Tansley

              Chief Financial Officer

United States securities and exchange commission logo
July 10, 2020
Denis Burger
Director
Trinity Biotech plc
2823 Girts Rd.
Jamestown, NY 14701
Re:Trinity Biotech plc
Registration Statement on Form F-3
Filed July 6, 2020
File No. 333-239701
Dear Mr. Burger:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Chris Edwards at (202) 551-6761 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Steven J. Glusband, Esq.

CORRESP
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    corresp.htm

Trinity Biotech plc Letterhead

May 9, 2017

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention: Jeffrey Gabor

Re:   Trinity Biotech plc

         Registration Statement on Form F-3

         File No. 333-203555

Dear Mr. Gabor:

The undersigned, on behalf of Trinity Biotech plc (“Trinity”), issuer of the securities covered by the above-referenced Registration Statement, hereby respectfully requests that the above-referenced Registration Statement be declared effective by the Securities and Exchange Commission at 4:00 p.m. Washington, D.C. time, on Thursday, May 11, 2017, or as soon thereafter as possible.

Management of Trinity is aware of its responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the disposition of the securities covered by the above-referenced Registration Statement.

Thank you very much for your courtesy in this matter.

Very truly yours,

/s/Ronan O’Caoimh

Chief Executive Officer

April 27, 2015

Via E -mail
Ronan O’Caoimh
Chairman and Chief Executive Officer
Trinity Biotech plc
IDA Business Park
Bray, Co. Wicklow
Ireland

Re: Trinity Biotech plc
  Registration Statement on Form F-3
Filed  April 22, 2015
  File No.  333-203555

Dear Mr. O’Caoimh :

This is to advise you that we have not  reviewed and will not review your registration
statement .

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are  in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

In the event you request acceleration of the effective date of the pending regist ration
statement , please provide  a written statement from the company acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action wit h respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in th e filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation

Ronan O’Caoimh
Trinity Biotech plc
April 27, 2015
Page 2

 of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the registered securities .

Please contact Matthew Jones  at (202) 551 -3786 or me at (202) 551 -3715  with any other
questions.

Sincerely,

 /s/ Daniel Greenspan for

Jeffrey P. Riedler
Assistant Director

cc: Alan J. Bernstein, Esq.
Carter Ledyard & Milburn LLP
2 Wall Street
New York, New York 10005

January 11, 2011
 Mr. Ronan O’Caoimh
Chief Executive Officer
Trinity Biotech, Plc.
IDA Business Park
Bray, Co. Wicklow, Ireland

Re: Trinity Biotech , Plc.
  Form 20- F for Fiscal Year Ended December 31, 2009
  File No. 000 -22320

Dear  Mr. O’Caoimh :
 We have completed our review of your Form 20- F and related filings and have no further
comments at this time.
 Sincerely,

Melissa Rocha
Accounting Branch Chief

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

Page 2

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

Page 4

November 23, 2010

Mr. Kevin Tansley
Chief Financial Officer
Trinity Biotech, plc
IDA Business Park
Bray, Co. Wicklow, Ireland
 Re:  Trinity Biotech, Plc.
Form 20-F for Fiscal Year Ended December 31, 2009 File No. 000-22320
 Dear Mr. Tansley:
 We have reviewed your November 5, 2010 resp onse to our September 27, 2010 letter and
have the following comments.

Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide this information.  Please furnish us a letter
on EDGAR under the form type label CORRESP th at keys your responses to our comments.
 After reviewing the information provided, we may raise additional comments and/or
request that you amend your filing.

Research and Products unde r Development, page 35

1. We acknowledge your response to our previous comm ents two and three.  It appears that the
disclosure of project costs you propose relate s to the projects that you capitalized in the
development phase under paragraph 57 of IAS 38.  Please revise your proposed disclosure to
disclose the significant projects in your research phase and, for each of them, please disclose the following information requested in our previous comment two:
• 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 inflow s from significant pr ojects are expected
to commence; and
• The risks and uncertainties associated with completing development on schedule and
the consequences to your operations, financia l position and liquidit y, if the project is
not completed on a timely basis.

If you do not maintain any research costs by pr oject, disclose that fact and explain why
management does not maintain and evaluate re search costs by project.  Provide other

Mr. Kevin Tansley
Trinity Biotech plc November 23, 2010 Page 2
quantitative or qualitative di sclosure that indicates th e amount of the company’s
resources being used on each project.

To the extent that you are unable to estimate costs and timing to complete the project,
disclose those facts and circumstances indi cating the uncertainties that preclude you from
making a reasonable estimate.

Notes to the Consolidated Financial Statements

Note 1: Basis of Preparation a nd Significant Accounting Policies

g) Intangibles, including research and development, page 72
2. Please revise your proposed disclo sure provided in response to comment three to revise your
listing of development costs capita lized during the periods presented to reconcile these costs
to your total development costs capitalized as indicated in the table on page 98.  In this
regard it appears that the info rmation you provide represents approximately 71% and 75% of
your 2009 and 2008 capitalized development costs.  To the extent you have other
development projects that you di d not identify, please aggregat e the expenditures for those
projects and disclose the criteria you used to specifically identify the projects you did.
u) Tax (current and deferred), page 77
3. We acknowledge your response to our previous comment four and your proposed disclosure
referencing the use of a valuation allowance.   Please explain to us how your use of a
valuation allowance against deferred tax assets is consistent with the guidance in paragraph
24 of IAS 12 to recognize deferred tax assets onl y to the extent it is probable the benefit will
be utilized.
 Note 9: Income Tax Expense / (Credit), page 91
4. We acknowledge your response to our previous comment five.  Please revise your proposed
disclosure regarding deferred tax assets not reco gnized to indicate, that in addition to having
no reversing deferred tax liability in the same ju risdiction, future taxable income in the same
jurisdiction is not probable, consistent with your response to our prev ious comment four.
Otherwise, please advise.
You may contact Mark Brunhof er, Review Accountant, at (202) 551-3638 if you have
questions regarding the comments.  In this rega rd, do not hesitate to contact me at (202) 551-
3679.
Sincerely,

Jim B. Rosenberg Senior Assistant Chief Accountant

CORRESP
1
filename1.htm

CORRESP

    Jim Rosenberg

    November 5, 2010

    Senior Assistant Chief Accountant

    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 September 27, 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

Patents and Licenses

“Please disclose the terms of your licensing arrangements and R&D outsourcing to third parties.
Also, expand your disclosure on page 34 to include estimated payments under these arrangements.”

Response

The following is the additional disclosures which are required in relation to licenses and R&D
outsourcing.

“Licenses (page 10)

Each of the key licensing arrangements terminates on the expiry of the last of the particular
licensed patents covered by the respective agreement, except in the case of one of the agreements
which expires in 2015. Each licensor has the right to terminate the arrangement in the event of
non-performance by Trinity Biotech. The key licensing arrangements requires the Group to pay a
royalty to the license holder which is based on sales of the products which utilize the relevant
technology being licensed. The royalty rates vary from 2% to 8.5% of sales. The total amount paid
by Trinity Biotech under key licensing arrangements in 2009 was US$899,000 (2008: US$755,000).”

Page 1

“Research and Development carried out by third parties (page 34)

In 2005 a software development company based in France was contracted to develop and enhance the
software in the Destiny Max instrument. Under the terms of the contract, all software developed by
the software development company is the property of Trinity Biotech. Fees were agreed for each
separate software development task and payment was made once a specific project milestone had been
achieved. A total of Eur110,000 (US$153,000) was paid to this software development company in 2009.
Additionally, a number of individuals acted as third party consultants working principally on the
Destiny Max, HPLC and Tristat instruments. The total amount paid to R&D consultants in 2009 was
US$372,000.”

Query 2

Research and Products under Development (page 35)

“For each of your research and development projects, 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.”

Response

For the principal projects noted in the Research and Products under Development section in Item 5,
the following additional information will be disclosed:

    •

    Details of costs incurred for the years presented

    •

    Estimated costs to complete and the anticipated timing of those costs

    •

    Estimated date of completion and start of income generation

    •

    Risks and uncertainties associated with the planned completion dates and the
consequences if projects are not completed on a timely basis

The following is the additional disclosure:

“The following table sets forth for each of the main development projects, the costs incurred
during each period presented and the cumulative costs incurred as at 31 December 2009:

Page 2

    Total project

    costs to

    December 31,

    Product Name

    2009

    2008

    2009

    US$’000

    US$’000

    US$’000

    Destiny Max coagulation instrument

    3,234

    4,508

    13,730

    Tristat point of care instrument

    1,072

    823

    3,776

    HPLC Instrument for Haemoglobin A1c
testing

    1,023

    672

    1,813

    Trinblot Scanner

    72

    352

    577

    Bordetella Pertussis Western Blot test

    156

    0

    156

The costs in the foregoing table mainly comprise the cost of internal resources, such as the
payroll costs for the development teams and attributable overheads. The remainder mainly comprises
materials, consumables and third party consultants’ costs.”

“The following table sets forth the estimated cost to complete each of the main development
projects. Of the total estimated completion cost of US$4,510,000, US$3,110,000 is expected to be
incurred in 2010 and the remaining US$1,400,000 in 2011.

    Estimated

    Total costs

    date for

    Product Name

    to complete

    completion

    US$’000

    US$’000

    Destiny Max coagulation instrument

    460

    2010

    Tristat Instrument

    600

    2011

    Trinblot Scanner

    50

    2010

    Bordetella Pertussis Western Blot test

    400

    2010

    HPLC Instrument for Haemoglobin A1c testing

    3,000

    2011

Page 3

There are inherent risks and uncertainties associated with completing development projects on
schedule. In our experience the main risks to the achievement of a project’s planned completion
date occur primarily during the product’s verification and validation phase. During this phase the
product must attain successful results from in-house product testing and from third party clinical
trials. Obtaining regulatory approval on a timely basis is another variable in achieving a
project’s planned completion date.

We acknowledge that some aspects of a new product development are to an extent outside of the
control of the Group. Notwithstanding the uncertainty surrounding these external factors, we
believe the planned completion dates of these projects are realistic and achievable. If major
development projects were severely delayed, in our opinion it would not impact significantly on
Trinity Biotech’s financial position or on the capitalization criteria. As the manufacturing lead
time for these new products is relatively short, it is anticipated that material cash inflows will
commence shortly after each of the project’s planned completion date.”

Query 3

Basis of preparation and Significant Accounting Policies

g) Intangibles, including research and development, page 72

“Refer to your policy for research and development expenditures. Please revise to clarify how you
determine technical feasibility, commercial viability and cost recovery for a project as a basis
for concluding that the project has moved from a research to a development phase. Explain your
basis for utilizing a 15 year amortization period, when many of your projects are not protected by
specific patents. Also, identify those projects supporting development costs capitalized in 2009
and 2008 (i.e. $7.8 million and $8.4 million, respectively) and disclose the factors supporting
your conclusions that these projects were technically feasible, commercially viable and likely to
produce future economic benefits.”

Response

Intangibles accounting policy note

The following additional disclosure will follow after the first paragraph of the existing
intangibles accounting policy on page 72:

“The technical feasibility of a new product is determined by a specific feasibility study
undertaken at the first stage of any development project. The majority of our new product
developments involve the transfer of existing product know-how to a new application. Since the
technology is already proven in an existing product which is being used by customers, this
facilitates the proving of the technical feasibility of that same technology in a new product. The
results of the feasibility study are reviewed by a design review committee comprising senior
managers. The feasibility study occurs in the initial research phase of a project and costs in this
phase are not capitalized.

Page 4

The commercial feasibility of a new product is determined by preparing a discounted cash flow
projection. This projection compares the discounted sales revenues for future periods with the
relevant costs. As part of preparing the cash flow projection, the size of the relevant market is
determined, feedback is sought from customers and the strength of the proposed new product is
assessed against competitors’ offerings. Once the technical and commercial feasibility has been
established and the project has been approved for commencement, the project moves into the
development phase.”

On page 73, we intend to add the following additional information explaining our use of the 15 year
amortization period for capitalized development costs.

“Capitalized development costs

The Group uses a useful economic life of 15 years for capitalized development costs. This is a
conservative estimate of the likely life of the products. The Group is confident that products have
a minimum of 15 years life given the inertia that characterizes the medical diagnostics industry
and the barriers to entry into the industry. The following factors have been considered in
estimating the useful life of developed products:

    (a)

    once a diagnostic test becomes established, customers are reluctant to change to new
technology until it is fully proven, thus resulting in relatively long product life cycles.
There is also reluctance in customers to change to a new product as it can be costly both
in terms of the initial changeover cost and as new technology is typically more expensive.

    (b)

    demand for the diagnostic tests is enduring and robust within a wide geographic base.
The diseases that the products diagnose are widely prevalent (HIV, diabetes and Chlamydia
being just three examples) in many countries. There is a general consensus that these
diseases will continue to be widely prevalent in the future.

    (c)

    there are significant barriers to new entrants in this industry. Patents and/or
licenses are in place for many of our products, though this is not the only barrier to
entry. There is a significant cost and time to develop new products, it is necessary to
obtain regulatory approval and tests are protected by proprietary know-how, manufacturing
techniques and trade secrets.”

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 and how we determine whether development costs can be capitalized.

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

Page 5

    Product Name

    2009

    2008

    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

    Trinblot Scanner

    72

    352

    Bordetella Pertussis Western Blot test

    156

    0

All of the development projects for which costs have been capitalized are judged to be technically
feasible, commercially viable and likely to produce future economic benefits. In reaching this
conclusion, many factors have been considered including the following:

    (a)

    The Group only develops products within its field of expertise. The R&D team is
experienced in developing new products in this field and this experience means that only
products which have a high probability of technical success are put forward for
consideration as potential new products.

    (b)

    A technical feasibility study is undertaken in advance of every project. The
feasibility study for each project is reviewed by the R&D team leader, and by other senior
management depending on the size of the project. The feasibility study occurs in the
initial research phase of the project and costs in this phase are not capitalized.

    (c)

    Nearly all of our new product developments involve the transfer of our existing product
know-how to a new application. The Group does not engage in pure research. Every
development project is undertaken with the intention of bringing a particular new product
to market for which there is a known demand.

    (d)

    The commercial feasibility of each new product is established prior to commencement of
a project by ensuring it is projected to achieve an acceptable income after applying
appropriate discount rates.”

Page 6

Query 4

Tax (current and deferred) pages 77, 93 and 101

“Please revise your policy regarding the recognition of deferred tax assets to specify, if true,
that you record these assets when it is probable that future taxable profits will be available to
utilize the associated losses or temporary differences under paragraphs 27 and 34 of IAS 12. In
addition, please revise Notes 9 and 13 so that the information provided in these disclosures is
consistent. For example:

    •

    on page 93, clarify the level of uncertainty prompting less than full recognition of
your deferred tax assets associated with the various tax losses and temporary differences;
and

    •

    on page 101, clarify why you recognize deferred tax assets only where there is a
reversing deferred tax liability in the same jurisdiction reversing in the same period.
Also, clarify whether you consider other sources of future taxable profits, and if not, why
not.”

Response

The accounting policy for current and deferred tax will be amended to include the following
statement:

“Deferred tax assets are recognised when it is probable that future taxable profits will be
available to utilize the associated losses or temporary differences.”

The level of uncertainty surrounding less than full recognition of deferred tax assets will be
explained by the following additional disclosure in note 9 (page 93).

“The deferred tax assets in the above table have not been recognized due to uncertainty regarding
the full utilization of these losses in the related tax jurisdiction in future periods. Only when
it is probable that future profits will be available to utilize the forward losses or temporary
differences is a deferred tax asset recognized. When estimating future profits or losses, past
performance is relevant and in this context we note that in UK and France, Trinity Biotech has no
history of taxable profits in these two countries mainly due to the current lack of scale of the
operations in these countries. There is considerable uncertainty over future taxable profits in UK
and France. Whereas in Germany, there have been individual years in which taxable profits have
arisen, there is no reliable pattern of profits which would suggest future profits are probable. In
USA there is a broad range of future income projections from losses to profits from which we
concluded there was not sufficient certainty to recognize a deferred tax asset.”

In note 12 (page 101), the existing disclosure in relation to recognised deferred tax assets and
liabilities will be amended to the following:

“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 first calculate the deferred tax asset. If the deferred tax asset is deemed not
to be recoverable, considering all sources
for future taxable profits, a valuation allowance is created to the extent it is considered not
recoverable.

September 27, 2010
 Mr. Ronan O’Caoimh
Chief Executive Officer
Trinity Biotech, Plc.
IDA Business Park
Bray, Co. Wicklow, Ireland
Re: Trinity Biotech, Plc.
  Form 20-F for Fiscal Year Ended December 31, 2009
  File No. 000-22320

Dear Mr. O’Caoimh:
 We have limited our review to only your fina ncial statements and related disclosures and
do not intend to expand our review to other por tions of your documents.  In our comments, we
ask you to provide us with information so  we may better underst and your disclosure.
 Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response.  Where a comment requests you to revise disclosu re, the information you provide s hould show us what the revised
disclosure will look like and identify the filing in which you intend to first include it.  If you do
not believe a comment applies to your facts a nd circumstances, please tell us why in your
response.  Please furnish us a letter on EDGAR under the form type label CORRESP that keys
your responses to our comments.
 After reviewing the information provided, we may raise additional comments and/or
request that you amend your filing.  Patents and Licenses, page 10

1. Please disclose the terms of your licensing arrangements and R&D outsourcing to third
parties.  Also, expand your disclosure on pa ge 34 to include estimated payments under
these arrangements.
 Research and Products unde r Development, page 35

2. For each of your research and development projects, please disclose the following
information.

• The costs incurred by you during each period presented and to date on the project;

Mr. Ronan O’Caoimh
Trinity Biotech, Plc. September 27, 2010 Page 2
• 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 inflow s from significant pr ojects are expected
to commence; and
• The risks and uncertainties associated with completing development on schedule and
the consequences to your operations, financia l position and liquidit y, if the project is
not completed on a timely basis.

If you do not maintain any research and develo pment costs by project, disclose that fact
and explain why management does not maintain  and evaluate resear ch and development
costs by project.  Provide other quantitative or  qualitative disclosure that indicates the
amount of the company’s resources being used on each project.  To the extent that you are unable to estimate costs and timing to complete the project, disclose those facts and circumstances indi cating the uncertainties that preclude you from
making a reasonable estimate.
 Notes to the Consolidated Financial Statements

 1.  Basis of Preparation and Significant Accounting Policies

 g) Intangibles, including research and development, page 72

3. Refer to your policy for research and developmen t expenditures.  Please  revise to clarify
how you determine technical feasibility, commer cial viability and cost recovery for a
project as a basis for concluding that the project has moved from a research to a
development phase.  Explain your basis for ut ilizing a 15-year amortization period, when
many of your projects are not protected by speci fic patents.  Also, identify those projects
supporting development costs capitalized in 2009 and 2008 (i.e. $7.8 million and $8.4 million, respectively) and disclose the fact ors supporting your conclusions that these
projects were technically feasible, commercia lly viable and likely to produce future
economic benefits.
u) Tax (current a nd deferred), page 77

4. Please revise your policy regarding the recogn ition of deferred tax as sets to specify, if
true, that you record these assets when it is probable that future ta xable profits will be
available to utilize the associated losses or temporary differences under paragraphs 27
and 34 of IAS 12.  In addition, please revise  Notes 9 and 13 so that the information
provided in these disclosures is consistent.  For example:

Mr. Ronan O’Caoimh
Trinity Biotech, Plc. September 27, 2010 Page 3
• on page 93, clarify the level of uncertainty  prompting less than full recognition of
your deferred tax assets associated with  the various tax losses and temporary
differences; and
• on page 101, clarify why you recognize deferre d tax assets only where there is a
reversing deferred tax liability  in the same jurisdiction re versing in the same period.
Also, clarify whether you consider other sour ces of future taxable profits, and if not,
why not.
 9.  Income Tax Expense (Credit), page 91

5. You disclose a 30.66% item in your rate r econciliation for 2009 rela ted to net operating
losses and temporary differences, for which no deferred tax assets were recognized.
Please revise your disclosure to clarif y what net operating losses and temporary
differences were not recognized and why.  In  addition, please revise your disclosure of
unrecognized deferred tax assets in Note 13 on page 101 to consis tently reflect your
revised disclosure in Note 9, explaining how th is reconciling item impacted the change in
unrecognized deferred tax assets during 2009.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in
the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
  In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;
• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
• the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Frank Wyman, Staff Accountant at (202) 551-3660 or Mark Brunhofer,
Accounting Reviewer at (202) 551-3638, if you have questions regarding these comments.  In
this regard, do not hesitate to contact me, at (202) 551-3679.

Sincerely,

Jim B. Rosenberg
Senior Assistant Chief Accountant

Via Facsimile and U.S. Mail
Mail Stop 4720
                                                                                                 March 17, 2010  Kevin Tansley Chief Financial Officer Trinity Biotech Plc, One Southern Cross,  IDA Business Park, Bray, Co Wicklow, Ireland
Re: Trinity Biotech plc
 Form 20-F for the Fiscal Year Ended December 31, 2008  Filed April 7, 2009  Form 20-F/A for the Fiscal Year Ended December 31, 2008  Filed March 4, 2010  File No. 000-22320

Dear Mr. Tansley:

 We have completed our review of your Form 20-F and related filings and have
no further comments at this time.

Sincerely,

Jeffrey P. Riedler Assistant Director

CORRESP
1
filename1.htm

Correspondence

March 5, 2010

Jeffrey P. Riedler

Assistant Director

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 Jeffrey,

In reference to your letter dated February 24, 2010, I confirm that we have now filed the following agreements as
exhibits:

    1.

    Acquisition agreement with Cortex Biochem Inc

    2.

    Acquisition agreement with Sterilab Services UK

We intend to list these two agreements along with the other agreements mentioned in my letter of February 16, 2010 in
the exhibit index in our next Form 20-F.

We acknowledge that:

    •

    it is the company’s responsibility for the adequacy and accuracy of the disclosure in its filings;

    •

    Commission staff comments or changes to disclosure in response to staff comments do not foreclose the
Commission from taking any action with respect to the filing; and

    •

    The company may not assert staff comments as a defense in any proceeding initiated by the Commission or
any person under the federal securities laws of the United States.

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.

Via Facsimile and U.S. Mail
Mail Stop 4720
                                                                                                 February 24, 2010  Kevin Tansley Chief Financial Officer Trinity Biotech Plc, One Southern Cross,  IDA Business Park, Bray, Co Wicklow, Ireland
Re: Trinity Biotech plc
 Form 20-F for the Year Ended December 31, 2008  Filed April 7, 2009  File No. 000-22320

Dear Mr. Tansley:

We have reviewed your February 16,  2010 response to our January 6, 2010
comment letter and have the following addi tional comment.  In our comment, we ask you
to provide us with information to better understand your disclosure.  Where it requests
you to revise disclosure, the information you provide should show us what the revised disclosure will look like and identify the a nnual or quarterly fili ng, as applicable, in
which you intend to first include  it.  If you do not believe th at revised disclosure is
necessary, explain the reason in your response.  After reviewing the information provided, we may raise additional comments and/or request that you amend your filing.

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

Item 19. Exhibits, page 134

1. We note your response to comment 1 of our letter dated January 6, 2010 and we
reissue the comment.  Please file copies of the following two agreements as
exhibits:
• September 2007 Acquisition Agreement with Cortex Biochem Inc.
• October 2007 Acquisition Agreem ent with Sterilab Services UK
Once filed, please list th ese agreements in the exhib it index of your next Form 20-
F filing, along with the agreements listed in the table provided in your February
16, 2010 response letter.

Kevin Tansley
Trinity Biotech plc February 24, 2010 Page 2
* * *

Please provide us the information request ed within 10 busine ss days or tell us
when you will provide us with a response.  Please furnish a cover letter with your response that keys your responses to our comment and provide any requested
information.  Detailed cover letters greatly facilitate our  review.  Please furnish your
letter on EDGAR under the form type label CORRESP.

 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our comment, please provide , in your letter, a
statement from the company acknowledging that:
• the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comment on your filing.
Please contact Laura Crotty, Staff Atto rney, at (202) 551-3575, Suzanne Hayes,
Legal Branch Chief, at (202) 551-3675 or my self at (202) 551-3715 if you have questions
regarding the processing of your response as well as any questions regarding comments
and related matters.

Sincerely,

Jeffrey P. Riedler Assistant Director

CORRESP
1
filename1.htm

Correspondence

February 16, 2010

Jeffrey P. Riedler

Assistant Director

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 Jeffrey,

Further to your letter to us dated January 6, 2010, please find our reply to the query.

Item 19 Exhibits, page 134

The following exhibits have been filed already:

    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.

I confirm that we intend to incorporate the agreements by reference into the exhibit index in our
Form 20-F for the year ended December 31, 2009.

Service contracts between Trinity Biotech and its Executive Directors and Officers are not required
to be publicly disclosed under Irish company law. For this reason, we will not be including them in
the list of exhibits in our 2009 Form 20-F for the fiscal year ended December 31, 2009.

We acknowledge that:

    •

    it is the company’s responsibility for the adequacy and accuracy of the disclosure in
its filings;

    •

    Commission staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and

    •

    The company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

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.

Via Facsimile and U.S. Mail
Mail Stop 4720
                                                                                                 January 6, 2010  Kevin Tansley Chief Financial Officer Trinity Biotech Plc, One Southern Cross,  IDA Business Park, Bray, Co Wicklow, Ireland
Re: Trinity Biotech plc
 Form 20-F for the Year Ended December 31, 2008  Filed April 7, 2009  File No. 000-22320

Dear Mr. Tansley:

We have reviewed your December 2 1, 2009 response to our December 9, 2009
comment letter and have the following addi tional comment.  In our comment, we ask you
to provide us with information to better understand your disclosure.  Where it requests
you to revise disclosure, the information you provide should show us what the revised disclosure will look like and identify the a nnual or quarterly fili ng, as applicable, in
which you intend to first include  it.  If you do not believe th at revised disclosure is
necessary, explain the reason in your response.  After reviewing the information provided, we may raise additional comments and/or request that you amend your filing.
 Form 20-F for the fiscal year ended December 31, 2008

 Item 19. Exhibits, page 134

1. We note your response to our prior comme nt 3; however, you have not indicated
your intent to file copies of the mate rial agreements disc ussed in our prior
comment 2 as exhibits.  Please file copies of these agreements as exhibits to the extent you have not already done so.  In the event these agreements have been filed, please advise us where they mi ght be found and confirm that you will
incorporate the agreements by reference in to the exhibit index of your next Form
20-F.
* * *

Kevin Tansley
Trinity Biotech plc January 6, 2010 Page 2

Please provide us the information request ed within 10 busine ss days or tell us
when you will provide us with a response.  Please furnish a cover letter with your response that keys your responses to our comment and provide any requested
information.  Detailed cover letters greatly facilitate our  review.  Please furnish your
letter on EDGAR under the form type label CORRESP.

 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our comment, please provide , in your letter, a
statement from the company acknowledging that:
• the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comment on your filing.
Please contact Laura Crotty, Staff Atto rney, at (202) 551-3575, Suzanne Hayes,
Legal Branch Chief, at (202) 551-3675 or my self at (202) 551-3715 if you have questions
regarding the processing of your response as well as any questions regarding comments
and related matters.

Sincerely,

Jeffrey P. Riedler Assistant Director

CORRESP
1
filename1.htm

CORRESP

December 21, 2009

Jeffrey P. Riedler

Assistant Director

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 Jeffrey,

Thank you for your letter dated December 9, 2009 and your assistance in helping to improve the
company’s Form 20-F disclosures. We acknowledge that:

    •

    it is the company’s responsibility for the adequacy and accuracy of the disclosure in
its filings;

    •

    Commission staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and

    •

    The company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

Please find my responses to the specific issues raised in your letter:

General

I confirm that our Form 20-F for the fiscal year ended December 31, 2009 will include the substance
of our responses as detailed in my letter dated November 12, 2009.

Material Contracts

We propose to disclose the following relevant information on material contracts in our Form 20-F
for the fiscal year ended December 31, 2009.

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.

The main terms and conditions in the Cortex purchase agreement were as follows:

    1.

    Trinity Biotech acquired Cortex’s lists of customers and suppliers, inventory
of immuno reagents, certain accounts receivable and accounts payable balances and the
Cortex Biochem website.

    2.

    The vendor undertook not to compete directly with the Cortex business for a
period of three years after the sale of the business to Trinity

    3.

    All of the purchase consideration was payable on signing of the contract.

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.

The main terms and conditions in the Sterilab purchase agreement were as follows:

    1.

    Trinity Biotech acquired a list of customers, inventory of infectious diseases
and autoimmune products and all diagnostic instruments placed with Sterilab’s customers

    2.

    The vendor undertook not to compete directly with Trinity’s infectious disease
business in the United Kingdom for a period of one year after the sale of the Sterilab
business to Trinity

    3.

    All of the purchase consideration was payable on signing of the contract.

Item 19 Exhibits, page 134

Service contracts between Trinity Biotech and its Executive Directors and Officers are not required
to be publicly disclosed under Irish company law. For this reason, we will not be including them in
the list of exhibits in our 2009 Form 20-F for the fiscal year ended December 31, 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.

Via Facsimile and U.S. Mail
Mail Stop 4720
                                                                                                 December 9, 2009  Kevin Tansley Chief Financial Officer Trinity Biotech Plc, One Southern Cross,  IDA Business Park, Bray, Co Wicklow, Ireland
Re: Trinity Biotech plc
 Form 20-F for the Year Ended December 31, 2008  Filed April 7, 2009  File No. 000-22320

Dear Mr. Tansley:

We have reviewed your November 12, 2009 response to our September 9, 2009
comment letter and have the following addi tional comments.  In our comments, we ask
you to provide us with information to be tter understand your di sclosure.  Where it
requests you to revise disclosure, the information you provide should show us what the revised disclosure will look like and identify the annual or quarterly filing, as applicable, in which you intend to first include it.  If you do not believe that revised disclosure is
necessary, explain the reason in your response.  After reviewing the information provided, we may raise additional comments and/or request that you amend your filing.
  Please understand that the purpose of our re view 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. Please confirm that you will include the s ubstance of your responses to our prior
comments 1, 2, 3 and 4 in your Form 20-F for the fiscal year ended December 31,
2009.

Kevin Tansley
Trinity Biotech plc December 9, 2009
Page 2  Material Contracts, page 49

2. We note your response to our prior comment 5 and we reissue the comment.  Please provide draft disclosure to be included in your Form 20-F for the fiscal year ended December 31, 2009 which incl udes a summary of the terms and
conditions of the two material contract s referenced in your response.  Your
disclosure should discuss each party’s rights and obligations under the agreements and the term and termination provisions, in  addition to any other terms material to
an investor’s understanding of the arrangements.
 Item 19. Exhibits, page 134

3. We note your response to our prior comment  7 and advise you that your exhibit
index should also include the service ag reements discussed in response to our
prior comment 3, unless such agreements are not required to  be filed by your
home country or are not otherwise pub licly disclosed, and the two material
contracts discussed in response to our pr ior comment 5.  Also, please file copies
of these agreements to the extent  you have not already done so.

* * *

Please provide us the information request ed within 10 busine ss days or tell us
when you will provide us with a response.  Please furnish a cover letter with your response that keys your responses to our  comments and provide any requested
information.  Detailed cover letters greatly facilitate our  review.  Please furnish your
letter on EDGAR under the form type label CORRESP.

 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our co mments, please provide, in your letter, a
statement from the company acknowledging that:
• the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

Kevin Tansley
Trinity Biotech plc December 9, 2009 Page 3
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comment on your filing.
Please contact Laura Crotty, Staff Atto rney, at (202) 551-3575, Suzanne Hayes,
Legal Branch Chief, at (202) 551-3675 or my self at (202) 551-3715 if you have questions
regarding the processing of your response as well as any questions regarding comments
and related matters.

Sincerely,

Jeffrey P. Riedler Assistant Director

CORRESP
1
filename1.htm

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.

CORRESP
1
filename1.htm

Correspondence

Ms. Laura Crotty

Securities & Exchange Commission

Washington D.C. 20549

USA

15 October 2009

    Ref:

    Trinity Biotech plc

Form 20-F for year ended December 31, 2008

Filed April 7, 2009

File no. 000-22320

Dear Ms. Crotty,

In reference to your letter dated September 9, 2009, I confirm that we intend to respond to the matters raised within
the next four weeks. The reason for the delay in replying is that I only received your letter today by mail. I did not
receive your faxed copy.

My fax number for future correspondence is +353 2769888.

Yours sincerely,

Kevin Tansley

Kevin Tansley

Chief Financial Officer

Trinity Biotech plc

Via Facsimile and U.S. Mail
Mail Stop 4720
                                                                                                 September 9, 2009  Kevin Tansley Chief Financial Officer IDA Business Park Bray, Co. Wicklow, Ireland
Re: Trinity Biotech plc
 Form 20-F for the Year Ended December 31, 2008  Filed April 7, 2009  File No. 000-22320

Dear Mr. Tansley:

We have reviewed your filing and have the following comments.  In our comments, we
ask you to provide us with information to bett er understand your disclosure.  Where it requests
you to revise disclosure, the information you provid e should show us what the revised disclosure
will look like and identify the annua l or quarterly filing, as applicable, in which you intend to
first include it.  If you do not believe that revi sed disclosure is necessa ry, explain the reason in
your response.  After reviewi ng the information provided, we may raise additional comments
and/or request that you amend your filing.   Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requir ements 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 aspe ct of our review.  Feel free to call us at
the telephone numbers listed at  the end of this letter.

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

Property, Plant and Equipment, page 13

1. Please revise your disclosure in this secti on 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 f acilities, how the assets are he ld and the products produced at
each facility.

Kevin Tansley
Trinity Biotech plc September 9, 2009 Page 2  Compensation of Director s and Officers, page 38

2. We note your statement on page 39 that “t he 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 expirati on 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.

3. Please provide the information require d by Item 6(C)(2) of Form 20-F.
 Stock Option Plan, page 40

4. 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.

Material Contracts, page 49

5. 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.

6. Please note that all registrants must provi de the information re quired by Item 16G of
Form 20-F beginning with the annual report that it files for its first fisc al year ended on or
after December 15, 2008.  Please revise your filing to include this information.
 Item 19. Exhibits, page 134

7. Please file all exhibits re quired by Item 19 of Form 20-F, including the company’s
articles of association, bylaws, material c ontracts including related party agreements, and
any other items applicable to the company.

*    *    *    *

Please provide us the information requested wi thin 10 business days or tell us when you
will provide us with a response.  Please furnish a cover letter with your response that keys your
responses to our comments and provide any reques ted information.  Detailed cover letters greatly
facilitate our review.  Please furnish your  letter on EDGAR under the form type label
CORRESP.

 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing in cludes all information re quired under the Securities
Exchange Act of 1934 and that they have provi ded all information investors require for an

Kevin Tansley
Trinity Biotech plc September 9, 2009 Page 3  informed investment decision.  Since the compa ny and its management are in possession of all
facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of
the disclosures they have made.     In connection with responding to our co mments, please provide, in your letter, a
statement from the company acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;
• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
• the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the sta ff of the Division of Corporati on Finance in our review of your
filing or in response to our comment on your filing.
Please contact Laura Crotty, Staff Attorne y, at (202) 551-3575, Suzanne Hayes, Legal
Branch Chief, at (202) 551-3675 or myself at (202) 551-3715 if you have questions regarding the
processing of your response as well as any que stions regarding comments and related matters.

Sincerely,

Jeffrey P. Riedler Assistant Director

Via Facsimile and U.S. Mail Mail Stop 6010                                                                                                  February 8, 2008   Mr. Ronan O’Caoimh Director and Chief Executive Officer Trinity Biotech Plc. IDA Business Park Bray, Co. Wicklow, Ireland
Re: Trinity Biotech Plc.
Form 20-F for the Fiscal Year Ended December 31, 2006 Filed May 8, 2007
 File No. 000-22320

Dear Mr. O’Caoimh:   We have completed our review of your Form 20-F for the period ended December 31, 2006 and have no further comment at this time.
        S i n c e r e l y ,

Jim Atkinson Accounting Branch Chief

<DOCUMENT>
<TYPE>CORRESP
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<TEXT>
                                                                January 24, 2008

Jim B. Rosenberg
Senior Assistant Chief Accountant
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, 2006
FILED MAY 8, 2007
FILE NO. 000-22320

Dear Mr. Rosenberg,

Following a telephone discussion with Ms. Kei Ino, Staff Accountant with the SEC
on December 7, 2007, please find some additional information to that which was
provided in our letters dated September 28, 2007 and November 8, 2007, which
were in response to your letter dated August 24, 2007.

26. BUSINESS COMBINATIONS

ITEM 18 FINANCIAL STATEMENTS, PAGE 54, NOTES TO THE CONSOLIDATED FINANCIAL
STATEMENTS

2006 ACQUISITIONS, PAGE 96

2. TO ASSIST US IN EVALUATING, FOR US GAAP PURPOSES, YOUR ACCOUNTING FOR THE
HAEMOSTASIS PRODUCT LINE ACQUIRED FROM BIOMERIEUX AS A BUSINESS COMBINATION
UNDER SFAS141 RATHER THAN AS AN ASSET ACQUISITION, PLEASE PROVIDE US AN ANALYSIS
UNDER PARAGRAPH SIX OF EITF 98-3 TO DEMONSTRATE HOW THE HAEMOSTASIS PRODUCT LINE
CONSTITUTES A BUSINESS. YOUR ANALYSIS SHOULD INCLUDE A LIST OF INPUTS, PROCESSES
AND OUTPUTS THAT WERE TRANSFERRED IN ORDER TO CONTINUE NORMAL OPERATIONS AND
SUSTAIN A REVENUE STREAM. IF ANY ELEMENT OF INPUTS, PROCESSES AND OUTPUTS AS
LISTED UNDER EITF 98-3 IS MISSING PROVIDE US A DISCUSSION AS TO HOW THE MISSING
ELEMENT IS NOT REQUIRED IN CONTINUING NORMAL OPERATIONS.

ADDITIONAL INFORMATION FROM TRINITY BIOTECH PLC:

As part of the acquisition accounting for bioMerieux the Company was required to
value identifiable intangible assets. Based on the criteria outlined in IFRS 3
and SFAS 141 two specific intangible assets were identified: customer
relationships and developed technology. In order to assist in this process the
Company commissioned an independent valuation specialist, Deloitte Financial
Advisory Services LLP ("Deloitte") to perform the valuation of these assets. The
following outlines the

<PAGE>

valuation methodology employed and represents the standard methodology employed
by Deloitte for such valuations.

CUSTOMER RELATIONSHIPS

Customer relationships were valued using an excess earnings methodology under
the income approach. This methodology calculates the net present value of the
future cashflows expected to be earned from those customers acquired as part of
the acquisition.

Revenues were projected forward for a period of 12 years from the date of
acquisition. These projections assumed a 7% annual level of customer attrition.
This assumption was based on the historic level of customer attrition during the
three and one half year period immediately prior to the acquisition. The
information required for this calculation was provided by bioMerieux and
consisted of detailed sales records by customer for the period in question.

In order to arrive at the cash generated from the customers, assumptions were
made for cost of goods sold and general and administrative expenses. These were
based on the respective costs being incurred by bioMerieux at the time of
acquisition.

In addition to the above expenses, a number of contributory asset charges have
been made against the above cashflows. These contributory asset charges are
included to ensure that the Company receives sufficient cashflows to provide a
fair return on the other assets employed in the business. The following
contributory asset charges were included in the valuation of the customer
relationships:
        o    Trade name
        o    Developed technologies
        o    Fixed assets
        o    Working capital, and
        o    Work force

Trade name

A return on a trade name was used in the valuation to reflect a fair return
associated with the use of a trade name in marketing the Company's products.
This is notwithstanding that Trinity Biotech plc did not acquire the bioMerieux
trade name but for valuation purposes it was appropriate to assume that the use
of a trade name would be necessary in order to compete effectively in the market
place. The charge for the use of a trade name was assumed to be 1% of revenues
(based on market rates).

Developed Technologies

A charge was taken for developed technologies (see below for the separate
valuation of such technologies). The rationale for this charge is that the
underlying technology plays an important role in attracting customers to the
Company. The charge is based on a market based royalty rate for the use of
technology and is consistent with the royalty rates used in the valuation of the
developed technology intangible asset (see below).

<PAGE>

Fixed Assets

A charge is taken to reflect a fair return on the fixed assets employed in the
business. In calculating this return it was assumed that the assets were 60%
funded by debt and 40% funded by equity. This was reflective of how companies
typically finance the purchase of such assets. The after tax return used was
11%, which equates to a charge of approximately 0.55% of revenues.

Working Capital

Similar to the fixed asset charge, the working capital charge reflects a fair
return on the working capital employed in the business. The rate of return used
was the prime rate at the acquisition date plus 200 basis points (i.e. a
reasonable premium to the prime rate to reflect the rate at which the assets
comprising the working capital balance could be securitized). This resulted in
an after tax return of 6.1%, which equates to a charge of approximately 2% of
revenues.

Workforce

A charge is taken for the Company's assembled workforce. The value of the work
force has been calculated using a cost approach whereby the cost of recreating a
comparable workforce is calculated. This includes the cost of recruiting and
training a new work force and the cost of lower productivity during the initial
training period. The charge amounted to 2.5% of revenues.

After taking into account each of the above the company had derived the future
cashflows expected to be generated from the acquired customers. A tax rate of
39.5% was then applied and the after tax cashflows were then discounted using a
discount rate reflective of the risks inherent in the acquired business. This
discount rate was calculated using the Capital Assets Pricing Model (CAPM). As a
final step in the valuation process, the tax amortization benefit of the
intangible asset (i.e. the customer relationship) was calculated.

Based on the above, the Company valued the customer relationships at the time of
acquisition at $6.2m.

DEVELOPED TECHNOLOGY

As part of the acquisition of bioMerieux, Trinity Biotech plc acquired
technology associated with reagents and instruments. Whilst some of the
technology is protected by patents, which were transferred to Trinity Biotech
plc, the technology acquired primarily consists of know how associated with the
manufacture of the products. This is particularly the case with respect to the
reagent technology acquired.

The value of the acquired technology was calculated using a relief-from-royalty
method. This method assumes that the value of the technology can be estimated by
calculating what royalty would have to be paid to a third party owner of
technology for its use if the Company did not own the technology. Thus the value
of the asset is the saving that the acquirer enjoys by virtue of owning the
technology rather than having to pay a royalty to a third party technology
owner. Royalty payments are calculated for the expected life of the technology
and the after tax amount discounted using an appropriate risk based discount
rate. As in the case of customer relationships as the final step in the
valuation process, the tax amortization benefit of the intangible asset (i.e.
the customer relationship) was calculated.

<PAGE>

In determining what royalty rate to use, a range of known royalty rates within
the industry were examined, which showed comparable royalties in the range of
2.5% to 7%.

For reagent technology, a royalty rate of 4%, or approximately the mid-point of
royalty rates observed, was used for the purposes of the valuation. It was
assumed that this royalty would be payable over the remaining life of the
technology. For the purposes of calculating this royalty it was assumed that the
revenues from the technology would remain constant for first 10 years, and would
then taper off over the next five years as the technology is replaced by new and
alternative technologies. Based on this, the valuation assigned to reagent
technology was $4.9 million.

With respect to instrument technology, a lower royalty rate of 3% and a shorter
life (3 years) was assumed as the technology in question was older and was
expected to be superceded by new instrument technology. Consequently the
valuation assigned to instrument technology was $50,000.

As previously mentioned to you, Trinity Biotech plc announced on December 7,
2007 that it was undertaking a Group restructuring and this will be accounted
for in the 2007 financial statements. We are currently in the process of
finalising our accounting for this restructuring. We furnished our press release
on this planned action on Form 6-K on December 17, 2007.

As part of its response to the request for further information, Trinity Biotech
plc acknowledges the following:

     o    Trinity  Biotech plc is  responsible  for the adequacy and accuracy of
          the disclosure in this filing;

     o    Staff  comments or changes to disclosure in response to staff comments
          do not foreclose the Commission from taking any action with respect to
          the filing; and

     o    Trinity  Biotech plc may not assert staff comments as a defense in any
          proceeding initiated by the Commission or any person under the federal
          securities laws of the United States.

In the event that you have any queries please contact me at +353 1 2769864.

Yours sincerely

/s/ Kevin Tansley
Kevin Tansley
Chief Financial Officer
Trinity Biotech plc.

</TEXT>
</DOCUMENT>

<DOCUMENT>
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<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

                                                                8 November, 2007

Jim B. Rosenberg
Senior Assistant Chief Accountant
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, 2006
FILED MAY 8, 2007
FILE NO. 000-22320

Dear Mr. Rosenberg,

Following a telephone discussion with Ms. Kei Ino, Staff Accountant with the SEC
on October 19, 2007, please find some additional information to that which was
provided in our letter dated September 28, 2007, which was a response to your
letter dated August 24, 2007.

Original Query

ITEM 18 FINANCIAL STATEMENTS, PAGE 54
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

1. BASIS OF PREPARATION AND SIGNIFICANT ACCOUNTING POLICIES G) INTANGIBLES,
INCLUDING RESEARCH AND DEVELOPMENT (OTHER THAN GOODWILL)

RESEARCH AND DEVELOPMENT, PAGE 63

1. PLEASE PROVIDE US A LIST OF THE ACTIVITIES (COMPLETED AND NOT COMPLETED) AND
THEIR CAPITALIZED AMOUNTS THAT COMPRISE THE $18,240,000 OF "DEVELOPMENT COSTS"
AT DECEMBER 31, 2006 AS INDICATED IN NOTE 11. FOR EACH ACTIVITY (COMPLETED AND
NOT COMPLETED TELL US THE DATE CAPITALIZED, THE NATURE OF THE ACTIVITY AND
ADDRESS HOW YOU MET EACH OF THE CRITERIA IN PARAGRAPH 57 OF IAS 38. FOR
ACTIVITIES NOT COMPLETED AT DECEMBER 31, 2006, ALSO TELL US THE NATURE AND
DOLLAR AMOUNT AND TIMING OF EFFORTS REMAINING TO BE COMPLETED.

ADDITIONAL INFORMATION FROM TRINITY BIOTECH PLC:

The Company provides the following supplemental information to that which was
included in its 2006 Form 20-F:
"Included within development costs are costs of US$11,282,000 which were not
amortised in 2006 (2005: US$6,280,000). These development costs are not being
amortised as the projects to which the costs related were not fully complete at
December 31, 2006 or at December 31, 2005. As at December 31, 2006 these

                                       1

<PAGE>

projects are expected to be completed during the period from January 1, 2007 to
December 31, 2009 at an expected approximate cost of a further US$9 million."

Subject to your satisfaction with this response it is our intention that all
future filings of the Form 20-F will include similar information, commencing
with the Company's Form 20-F for the fiscal year ended December 31, 2007, as
follows:

"Included within development costs are costs of US$XX,XXX,000 which were not
amortised in 2007 (2006: US$11,282,000). These development costs are not being
amortised as the projects to which the costs related were not fully complete at
December 31, 2007 or at December 31, 2006. As at December 31, 2007 these
projects are expected to be completed during the period from January 1, 2008 to
December 31, 20XX at an expected approximate cost of a further US$X million."

26. BUSINESS COMBINATIONS

2006 ACQUISITIONS, PAGE 96

2. TO ASSIST US IN EVALUATING, FOR US GAAP PURPOSES, YOUR ACCOUNTING FOR THE
HAEMOSTASIS PRODUCT LINE ACQUIRED FROM BIOMERIEUX AS A BUSINESS COMBINATION
UNDER SFAS141 RATHER THAN AS AN ASSET ACQUISITION, PLEASE PROVIDE US AN ANALYSIS
UNDER PARAGRAPH SIX OF EITF 98-3 TO DEMONSTRATE HOW THE HAEMOSTASIS PRODUCT LINE
CONSTITUTES A BUSINESS. YOUR ANALYSIS SHOULD INCLUDE A LIST OF INPUTS, PROCESSES
AND OUTPUTS THAT WERE TRANSFERRED IN ORDER TO CONTINUE NORMAL OPERATIONS AND
SUSTAIN A REVENUE STREAM. IF ANY ELEMENT OF INPUTS, PROCESSES AND OUTPUTS AS
LISTED UNDER EITF 98-3 IS MISSING PROVIDE US A DISCUSSION AS TO HOW THE MISSING
ELEMENT IS NOT REQUIRED IN CONTINUING NORMAL OPERATIONS.

ADDITIONAL INFORMATION FROM TRINITY BIOTECH PLC:

As part of the accounting for the acquisition of the haemostasis product line of
bioMerieux, the Company identified Developed Technology and Customer
Relationships as acquired intangible assets on the following basis:

     o    Developed Technology - this included the know-how necessary to
          manufacture the products.

     o    Customer Relationships - as part of the acquisition, the Company
          received details of the customers of the acquired bioMerieux products
          and a number of years of historic sales data. In  addition,
          bioMerieux's beneficial interest in its haemostasis sales contracts
          were transferred to the Company.

The Company did not value a trade name as part of the valuation process as it
did not acquire the rights to use the bioMerieux name (the Company only acquired
a small portion of the overall bioMerieux business with the remainder remaining
with bioMerieux) and none of the individual product names were deemed to have a
significant value in their own right. As has been mentioned above the key
intangible assets acquired concerned the developed technology itself and the
customer relationships rather than any particular profile associated with any
brand or product name in the market place.

                                       2

<PAGE>

The goodwill of US$21,002,000 arising on the transaction to acquire the
haemostasis product line from bioMerieux is attributable to future synergies
that will accrue to Trinity Biotech plc. These synergies arise due to the
increased scale that this acquisition brings to Trinity Biotech's already
established haemostasis business which includes both the manufacture and sale of
haemostasis diagnostic products. These synergies consist of two principal
categories as follows:

     o    Production synergies; and
     o    Selling synergies.

Production synergies

Prior to the acquisition of the bioMerieux range of products, Trinity Biotech
was already manufacturing its own range of haemostasis products. The vast
majority of these products were being manufactured in the Company's production
facility in Bray Ireland. By transferring the production of the bioMerieux
products to this facility, in conjunction with the rationalisation of the
combined haemostasis product line, economies of scale and inherent operating
efficiencies were envisaged. Specifically this was to be achieved by culling
products where there was an overlap between the Company's existing products and
the newly acquired products. This would enable the Company to manufacture larger
batches of the products which were to remain. The nature of the haemostasis
business is that very little incremental labour is required when moving from an
existing batch size to a larger one. Similarly there are non-labour cost
efficiencies associated with moving to larger batch sizes.

At the time of acquisition it was anticipated that an additional 30
manufacturing and support employees would be required in the Company's Bray
plant to manufacture the combined product ranges. This compares to the
approximately 65 employees that would be required to run a stand alone
manufacturing operation. The latter is based on the number of employees that
were employed at the bioMerieux facility in North Carolina. Thus, the Company
has an effective saving of 35 heads. Over a five year period, which is
considered a reasonable period to value such synergies it has been estimated
that the discounted value of these synergies is in excess of US$10 million. This
is based on the cost of the saved heads (including salaries, benefits etc.) plus
a reasonable level of overhead.

Selling Synergies

At the time of acquisition the Company had direct sales forces in the USA, UK
and Germany. These countries represent three of the largest diagnostic markets
in the world, accounting for approximately 60% of the worldwide market. It was
identified at the time of acquisition that the addition of the bioMerieux
products would not require the addition of significant sales resources to the
Company.

At the time of acquisition it was anticipated that an additional 44 sales,
instrument servicing and support employees would be required in the Company's
direct selling forces in order to promote and sell the newly combined range of
products. This compares to the approximately 116 employees that has been
estimated would be required to run stand alone selling functions in these
markets. Thus, the Company has an effective saving of 72 heads. Over a five year
period, which is considered a reasonable period to value such synergies, it has
been estimated that the discounted

                                       3

<PAGE>

value of these selling related synergies is in excess of US$15 million. This is
based on the cost of the saved heads (including salaries, benefits etc.) plus a
reasonable level of non-salary costs, such as travel and office expenses.

In summary, the value of the future synergies identified due to the acquisition
of the bioMerieux haemostasis product line were in excess of $25 million
(production synergies in excess of US$10 million and sales related synergies in
excess of US$15 million) which compares to identified goodwill of US$21,002,000.

The existence of both manufacturing and selling synergies at the time of the
acquisition ensured that the bioMerieux haemostasis product line had a value in
excess of the fixed, net current and identified intangible assets.
Consequentially, the Company was in a position to pay a significant premium
above the value of the assets identified. It can be argued that companies
without an existing haemostasis business would not be in a position to pay such
a premium as the synergies identified above would not accrue to such an
acquirer.

As part of its response to request for further information Trinity Biotech plc
acknowledges the following:

     o    Trinity Biotech plc is responsible for the adequacy and accuracy of
          the disclosure in this filing;

     o    Staff comments or changes to disclosure in response to staff comments
          do not foreclose the Commission from taking any action with respect to
          the filing; and

     o    Trinity Biotech plc may not assert staff comments as a defense in any
          proceeding initiated by the Commission or any person under the federal
          securities laws of the United States.

In the event that you have any queries please contact me or my colleague Kevin
Tansley at +353 1 2769800.

YOURS SINCERELY

/s/Rory Nealon
RORY NEALON
CHIEF FINANCIAL OFFICER
TRINITY BIOTECH PLC.

                                       4

</TEXT>
</DOCUMENT>

Via Facsimile and U.S. Mail Mail Stop 6010                                                                                                   August 24, 2007   Mr. Ronan O’Caoimh Director and Chief Executive Officer Trinity Biotech Plc. IDA Business Park Bray, Co. Wicklow, Ireland
Re: Trinity Biotech Plc.
Form 20-F for the Fiscal Year Ended December 31, 2006 Filed May 8, 2007
 File No. 000-22320

Dear Mr. O’Caoimh:
We have reviewed your filing and have the following comments.  We have
limited our review to only your financial stat ements and related disclosures and do not
intend to expand our review to  other portions of your docum ent.  In our comments, we
ask you to provide us with information so we may better understa nd your disclosure.
After reviewing this information, we may raise additional comments.    Please understand that the purpose of our re view 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.
 Item 18.  Finical Statements, page 54

Notes to the Consolidated Financial Statements
 1.  Basis of Preparation and Significant Accounting Policies

g)  Intangibles, Including Research and Development (Other Than Goodwill)

 Research and development, page 63

1. Please provide us a list of the activities (completed and not completed) and their
capitalized amounts that comprise the $18,240,000 of “Development costs” at
December 31, 2006 as indicated in Note 11. For each activity (completed and not

Mr. Ronan O’Caoimh
Trinity Biotech Plc. August 24, 2007 Page 2
 completed), tell us the date capitalized, th e nature of the activ ity and address how
you met each of the criteria in paragr aph 57 of IAS 38.  For activities not
completed at December 31, 2006, also tell us the nature, dollar amount and timing of efforts remaining to be completed.
 26.  Business Combinations

2006 Acquisitions, page 96

2. To assist us in evaluating, for US GAAP purposes, your accounting for the
haemostis product line acquired from bioMerieux as a business combination
under SFAS 141 rather than as an asset acq uisition, please provide us an analysis
under paragraph six of EITF 98-3 to de monstrate how the haemostasis product
line constitutes a business.   Your analysis should include a list of inputs,
processes and outputs that we re transferred in order to continue normal operations
and sustain a revenue stream.  If any el ement of inputs, processes and outputs as
listed under EITF 98-3 is missing, provide us a discussion as to how the missing
element is not required in continuing normal operations.

*    *    *    *

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please furnish a letter that  keys your responses to our
comments and provide the requested information.  Detailed letters gr eatly facilitate our
review.  Please furnish your letter on EDGAR under the form type label CORRESP.
  We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our co mments, please provide, in your letter, a
statement from the company acknowledging that:
• the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

Mr. Ronan O’Caoimh
Trinity Biotech Plc. August 24, 2007 Page 3

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
You may contact Kei Ino, Staff Accountan t, at (202) 551-3659 or Jim Atkinson,
Accounting Branch Chief, at (202) 551- 3674 if you have questions regarding the
comments.  In this regard, do not hes itate to contact me, at (202) 551-3679.

Sincerely,

Jim B. Rosenberg Senior Assistant Chief Accountant

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

                                                              September 28, 2007

Jim B. Rosenberg
Senior Assistant Chief Accountant
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, 2006
FILED MAY 8, 2007
FILE NO. 000-22320

Dear Mr. Rosenberg,

I am responding to your letter dated August 24, 2007. With respect to each of
your queries I have included the query as contained in your letter and given our
response directly below.

ITEM 18 FINANCIAL STATEMENTS, PAGE 54
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

1. BASIS OF PREPARATION AND SIGNIFICANT ACCOUNTING POLICIES
g) INTANGIBLES, INCLUDING RESEARCH AND DEVELOPMENT (OTHER THAN GOODWILL)

RESEARCH AND DEVELOPMENT, PAGE 63

1. PLEASE PROVIDE US A LIST OF THE ACTIVITIES (COMPLETED AND NOT COMPLETED) AND
THEIR CAPITALIZED AMOUNTS THAT COMPRISE THE $18,240,000 OF "DEVELOPMENT COSTS"
AT DECEMBER 31, 2006 AS INDICATED IN NOTE 11. FOR EACH ACTIVITY (COMPLETED AND
NOT COMPLETED TELL US THE DATE CAPITALIZED, THE NATURE OF THE ACTIVITY AND
ADDRESS HOW YOU MET EACH OF THE CRITERIA IN PARAGRAPH 57 OF IAS 38. FOR
ACTIVITIES NOT COMPLETED AT DECEMBER 31, 2006, ALSO TELL US THE NATURE AND
DOLLAR AMOUNT AND TIMING OF EFFORTS REMAINING TO BE COMPLETED.

TRINITY BIOTECH PLC RESPONSE

Under IFRS as adopted by the EU, Trinity Biotech Plc (`the Company') writes off
research and development expenditure as incurred, with the exception of
expenditure on projects whose outcome has been assessed with reasonable
certainty as to technical feasibility, commercial viability and recovery of
costs through future revenues. Such expenditure is capitalised at cost within
intangible assets as Development Costs and as at December 31, 2006 the total
amount capitalized was $18,240,000.

The following table includes a list of the significant projects that make up
this amount and the date on which the project was fully capitalised (except
where the project is incomplete). In summary all of the projects detailed below
relate to the development

                                       1

<PAGE>

of new or substantially improved diagnostic test kits or supporting diagnostic
instrumentation.

PROJECT                                                 AMOUNT
                                                   CAPITALISED     DATE FULLY
                                                   AT DECEMBER   CAPITALISED*
                                                      31, 2006
                                                        $'000
------------------------------------------------------------------------------
UniGold HIV Point of Care                                3,804           2005
------------------------------------------------------------------------------
Destiny Max                                              3,303     Incomplete
------------------------------------------------------------------------------
HIV Western Blot                                         2,135     Incomplete
------------------------------------------------------------------------------
Tri-Stat Point of Care A1c                               1,269     Incomplete
------------------------------------------------------------------------------
Flu Direct Fluorescent Assay                               965     Incomplete
------------------------------------------------------------------------------
Captia                                                     647           2005
------------------------------------------------------------------------------
Destiny Instrument (Plus and Opt versions)                 569           2004
------------------------------------------------------------------------------
US Lyme                                                    526     Incomplete
------------------------------------------------------------------------------
EU Lyme Western Blot                                       509           2005
------------------------------------------------------------------------------
D-Dimer Development                                        495     Incomplete
------------------------------------------------------------------------------
Legionella                                                 487     Incomplete
------------------------------------------------------------------------------
Haemostasis Product Range  Enhancement Project             428           2006
------------------------------------------------------------------------------
HBA1c - Haemoglobin                                        200     Incomplete
------------------------------------------------------------------------------
HSV Specific                                               184           2005
------------------------------------------------------------------------------
44 Kits                                                    166           2005
------------------------------------------------------------------------------
Reagent/Instrument Application Development                 153           2006
------------------------------------------------------------------------------
Other projects**                                         2,400
------------------------------------------------------------------------------
TOTAL                                                   18,240
------------------------------------------------------------------------------
* As of December 31, 2006
**Other projects consist of a range of projects whose individual capitalised
amounts are individually less than $150,000. It consists of a combination of
projects which have been completed ($498,000) and are yet to be completed
($1,902,000).

With respect to the projects which have been completed the Company has commenced
amortising the costs over the expected life of the product. As at December 31,
2006 the amount amortised was $950,000.

In response to your query the following outlines the nature of the activities
being undertaken and how the criteria outlined in paragraph 57 of IAS 38 are
met.

NATURE OF THE ACTIVITY

The nature of the activities being undertaken in these projects are principally
     (i)      the development of new diagnostic kits. This mainly consists of
              kits which test for conditions for which the Company does not
              already possess a test. However, in some cases the Company also
              develops an alternative test kit for a condition which the Company
              already has a test kit in order to increase the range of products
              which it can offer to customers.
     (ii)     the substantial improvement of existing products. These
              improvements relate to the accuracy and/or functionality of an
              existing test kit with a view to achieving additional sales.

                                       2

<PAGE>

CAPITALISATION CRITERIA PER PARAGRAPH 57 OF IAS 38

Technical feasibility of completing the asset so that it will be available for
use or sale

The Company carefully selects the development projects which it undertakes. One
of the key criteria for selection is the project's technical feasibility. Given
the finite availability of resources, only those projects which are considered
technically feasible are undertaken. For the most part the Company uses
technology that it already possesses with a view to expanding the range of
products that operate off a particular platform e.g. the Company's Western Blot
Lyme and Unigold HIV Point of care products form the basis for the new HIV
Western Blot project. Given the detailed knowledge of the technology and its
potential applications the Company is in a position to determine with a high
degree of certainty whether a project is technically feasible or not. The
ultimate determination is made by the Group Head of Research and Development who
has a long history of working in the diagnostics industry and who has an
in-depth knowledge of the technology at the Group's disposal. To date the
Company has not had a situation whereby it was unable to complete a project
after it had been determined to be technically feasible.

Intention to complete the intangible asset and use or sell it

The Company only undertakes projects that it intends to complete. Each project
has a defined objective to develop a new or substantially improved product for
sale to end user customers in the healthcare sector.

Ability to use or sell the intangible asset

The identification of development projects arises from the identification of a
market opportunity and/or gap in the Company's portfolio of diagnostic test
kits. Thus at the outset of the project it is assessed whether there is a market
for the product. This assessment is based on the detailed knowledge of the
market place which is contained within the Company's Sales and Marketing
function by the central and local sales personnel and dedicated product
managers. In some cases this knowledge will be supplemented with market
information supplied by third parties.

In the case of substantial improvements to existing products the Company already
has a very detailed knowledge of the market place and hence the ability to sell
the product. In particular, the Company has a knowledge of customers' demands
for improvements which it monitors closely, especially in the context of
advances being made by competitors in the industry.

Once projects are completed the Company sells the products to end user customers
in the healthcare sector. The Company has direct sales forces in 4 countries,
covering 65% of the world diagnostics market, and an extensive network of
approximately 300 distributors in a further 75 countries, all of which serve as
outlets for its products. The Company typically sells newly developed products
to its existing customer base in existing markets.

                                       3

<PAGE>

How the intangible asset will generate probable future economic benefits

Once developed, new or substantially improved products generate future economic
benefits for the Company through their sales to customers within the healthcare
sector. On average the Company's products have a gross margin of approximately
48%.

At the inception of each project (and annually thereafter) an assessment is made
as to whether the future economic benefits will be sufficient to recover the
ultimate cost of the development project. The total expected cost of the project
is calculated at inception based on the level of internal and external resources
expected to be applied to the project. Based on its knowledge of the market the
Company calculates the projected sales of the new/substantially improved
product. Using a combination of gross margins already being earned by similar
products and expectation of the likely cost of production the expected gross
margin percentage for the product is estimated. Given the variations which can
occur in both sales levels and gross margin percentage the Company adopts a
conservative approach when calculating these figures. The Company then
calculates the gross margin expected to be earned for each of the first five
years after the product is launched. The cashflows are discounted using a
discount rate which is reflective of the prevailing risk free rate as adjusted
for the uncertainties inherent in the product and market in question. These
discounted cashflows are then compared to the total expected cost of the project
to ensure that these costs are at least fully recovered.

Availability of adequate technical, financial and other resources to complete
the development and use or sell the intangible asset.

The Company has a significant number of product development specialists which
are located in the Company's facilities in Bray, Ireland, Jamestown, New York,
Carlsbad, California, Kansas City, Missouri and Lemgo, Germany. These
individuals are suitably qualified experts in their field. Given the depth of
expertise it possesses, the Company is not overly reliant on any single
individual for the completion of any project.

The funding for the projects is derived from the cash generated from the
Company's ongoing activities. The Company also has the ability to raise equity
and/or debt funding to support its development activities.

Ability to measure reliably the expenditure attributable to the intangible asset
during its development

The Company has put in place internal procedures for capturing costs during the
course of its projects. Internal staff costs are calculated based on the
completion of individual timesheets by the participants in the project. Based on
the time ascribed to the project an appropriate percentage of each individual's
salary cost and associated indirect costs is applied to the project. External
costs are captured as part of the Company's purchasing procedures whereby
individual purchases are coded to the relevant project/activity. This ensures
that all purchases are correctly allocated to the appropriate project.

                                       4

<PAGE>

SIGNIFICANT PROJECTS

In response to your query, please find enclosed specific details of the
Company's most significant projects. These are contained in Appendices 1 to 4 to
this letter as follows:

     -------------------------------------------------------------------------
            PROJECT                          APPENDIX         DATE FULLY
                                                            CAPITALISED OR
                                                              INCOMPLETE
     -------------------------------------------------------------------------
            UniGold HIV Point of Care           1                2005
     -------------------------------------------------------------------------
            Destiny Max                         2             Incomplete
      -------------------------------------------------------------------------
            HIV Western Blot                    3             Incomplete
     -------------------------------------------------------------------------
            Tri-Stat Point of Care A1c          4             Incomplete
     -------------------------------------------------------------------------

Details of these projects have been provided as in total they are the four most
significant projects undertaken by the Company and cumulatively represent 58% of
the amount capitalised as at December 31, 2006.

Each of the above appendices contains a description of the activity and the
method by which the projects were determined to have met the criteria contained
in paragraph 57 of IAS 38. In the case where the project was not complete as of
December 31, 2006 details of the estimated remaining effort and cost thereof
have been included. Of the remaining projects which account for 42% of the costs
capitalised 41% was in respect of projects which were completed as of December
2006. The remaining 59% was in respect of projects which were incomplete as at
December 31, 2006. In all cases these projects represent the development of new
or substantially improved diagnostic products. With respect to those projects
which were not complete as at December 31, 2006 they are expected to be
completed by December 31, 2009. The total expected cost to complete these
projects is approximately $4 million.

26. BUSINESS COMBINATIONS

2006 ACQUISITIONS, PAGE 96

2. TO ASSIST US IN EVALUATING, FOR US GAAP PURPOSES, YOUR ACCOUNTING FOR THE
HAEMOSTASIS PRODUCT LINE ACQUIRED FROM BIOMERIEUX AS A BUSINESS COMBINATION
UNDER SFAS141 RATHER THAN AS AN ASSET ACQUISITION, PLEASE PROVIDE US AN ANALYSIS
UNDER PARAGRAPH SIX OF EITF 98-3 TO DEMONSTRATE HOW THE HAEMOSTASIS PRODUCT LINE
CONSTITUTES A BUSINESS. YOUR ANALYSIS SHOULD INCLUDE A LIST OF INPUTS, PROCESSES
AND OUTPUTS THAT WERE TRANSFERRED IN ORDER TO CONTINUE NORMAL OPERATIONS AND
SUSTAIN

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mr Jim Rosenberg
Securities and Exchange Commission
100 First Street, N.E.
Washington DC
20549

September 11, 2007

Dear Mr. Rosenberg

In relation to your letter dated August 24, 2007 please be advised that Trinity
Biotech plc will respond no later than Friday, September 28, 2007. The delay in
response is due to the temporary lack of availability of key internal resources
arising from vacation.

Yours sincerely

/s/Rory Nealon
Rory Nealon
Chief Financial Officer
Trinity Biotech plc.

</TEXT>
</DOCUMENT>

Via Facsimile and U.S. Mail
Mail Stop 6010

February 21, 2007

Rory Nealon
Director/Chief Financial Officer
Trinity Biotech plc
IDA Business Park
Bray, CO. Wicklow, Ireland

Re: Trinity Biotech plc
 Form 20-F for Fiscal Year Ended December 31, 2005
 Filed March 31, 2006
 File No. 000-22320

Dear Mr. Nealon:

We have completed our review of your Form 20-F and have no further comments
at this time.

        S i n c e r e l y ,

        J i m  A t k i n s o n
        A c c o u n t i n g  B r a n c h  C h i e f

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

                                                                January 10, 2007

Jim B. Rosenberg
Senior Assistant Chief Accountant
United States Securities and Exchange Commission
450 Fifth Street N.W.
Washington D.C. 20549

RE: TRINITY BIOTECH PLC
FORM 20-F FOR THE FISCAL YEAR ENDED DECEMBER 31, 2005
FILED MARCH 31, 2006-10-05
FILE NO. 000-22320

Dear Mr. Rosenberg,

I am responding to your letter dated November 21, 2006. With regard to your
query I have included the query as contained in your letter and given our
response directly below.

ITEM 5 OPERATING AND FINANCIAL REVIEW AND PROSPECTS, PAGE 18
LIQUIDITY AND CAPITAL RESOURCES, PAGE 27
WORKING CAPITAL PAGE 28

YOUR RESPONSE TO OUR COMMENT TWO MERELY STATES THAT ACCOUNTS RECEIVABLE AT
DECEMBER, 2005 INCREASE BECAUSE SALES INCREASED. HOWEVER, IT APPEARS THAT
ACCOUNTS RECEIVABLE INCREASED AT A RATE GREATER THAN THE INCREASE IN SALES.
USING FOURTH QUARTER SALES WE COMPUTED DAYS' SALES IN TRADE RECEIVABLES AS 44
DAYS AT DECEMBER, 2004 AND 57 DAYS AT DECEMBER 31, 2005. PLEASE EXPLAIN THIS
INCREASE.

TRINITY BIOTECH PLC RESPONSE

MANAGEMENT OF TRINITY BIOTECH PLC PROPOSES TO AMEND PROSPECTIVELY ITS
DISCLOSURES IN ITS 2006 FORM 20-F. WE HAVE INCLUDED OUR PROPOSED REVISED
DISCLOSURE BELOW:

The increase in accounts receivable by US$8,034,000 was attributable to both
continuing activities and an acquisition. Accounts receivable at December 31,
2005 includes US$3,146,000 of accounts receivable in Primus, which was acquired
in July 2005. The credit terms offered by Primus are on average longer than the
credit terms given to customers in the rest of the Trinity Biotech Group. The
remaining increase of US$4,888,000 arose due to a combination of higher sales
levels in continuing group operations and slower collection rates attributable
to staff vacancies in the US finance function.

As part of its response to your letter Trinity Biotech plc acknowledges the
following:

     o    Trinity  Biotech plc is  responsible  for the adequacy and accuracy of
          the disclosure in this filing;

     o    Staff  comments or changes to disclosure in response to staff comments
          do not foreclose the Commission from taking any action with respect to
          the filing; and

     o    Trinity  Biotech plc may not assert staff comments as a defense in any
          proceeding initiated by the Commission or any person under the federal
          securities laws of the United States.

<PAGE>

Subject to your satisfaction with my response to your query as outlined in this
letter it is our intention that all future filings of the Form 20-F will include
similar information, commencing with the Company's Form 20-F for the fiscal year
ended December 31, 2006.

In the event that you have any queries please contact me or my colleague Kevin
Tansley at +353 1 2769800.

YOURS SINCERELY

/s/ Rory Nealon
RORY NEALON
CHIEF FINANCIAL OFFICER
TRINITY BIOTECH PLC.

</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mr James Peklenk
Securities and Exchange Commission
Washington DC
20549

December 28, 2006

Dear Mr. Peklenk

In relation to your letter dated November 28, 2006 please be advised that
Trinity Biotech plc will respond no later than Friday, January 12, 2007.

Yours sincerely

/s/ Rory Nealon
Rory Nealon
Chief Financial Officer
Trinity Biotech plc.

</TEXT>
</DOCUMENT>

Via Facsimile and U.S. Mail
Mail Stop 6010

                                                                                                November 28, 2006

Rory Nealon
Director/Chief Financial Officer
Trinity Biotech plc
IDA Business Park
Bray, CO. Wicklow, Ireland

Re: Trinity Biotech plc
 Form 20-F for Fiscal Year Ended December 31, 2005
 Filed March 31, 2006
 File No. 000-22320

Dear Mr. Nealon:

We have reviewed your October 6, 2006 response to our September 21, 2006
letter and have the following additional comm ent. In our comment, we ask you to provide
us with information so we may better understa nd your disclosure.  Please be as detailed
as necessary in your explanation.  After reviewing this information, we may raise
additional comments.

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

Item 5.  Operating And Financial Review And Prospects, page 18
Liquidity And Capital Resources, page 27
Working Capital, page 28
1. Your response to our comment two merely states that accounts receivable at December 31, 2005 increased because sales increased.  However, it appears that accounts receivable increased at a rate grea ter than the increase  in sales.  Using
fourth quarter sales we computed days’ sa les in trade receivables as 44 days at
December 31, 2004 and 57 days at December 31, 2005.  Please explain this increase.

*    *    *    *

Rory Nealon
Trinity Biotech plc
November 28, 2006 Page 2

Please respond to this comment within 10 business days or tell us when you will
provide us with a response.  Please furnish a letter that keys your responses to our
comment and provide the request ed information.  Detailed le tters greatly facilitate our
review.  You should furnish the letter to  us via EDGAR under the form type label
CORRESP.

You may contact James Pe klenk, Staff Accountant, at (202) 551-3661, or Lisa
Vanjoske, Assistant Chief Accountant, at ( 202) 551-3614 if you have questions regarding
the comment.  In this regard, do not he sitate to contact me, at (202) 551-3679.

Sincerely,

Jim B. Rosenberg
Senior Assistant Chief Accountant

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

                                                                 October 6, 2006

Jim B. Rosenberg
Senior Assistant Chief Accountant
United States Securities and Exchange Commission
450 Fifth Street N.W.
Washington D.C. 20549

RE: TRINITY BIOTECH PLC
FORM 20-F FOR THE FISCAL YEAR ENDED DECEMBER 31, 2005
FILED MARCH 31, 2006-10-05
FILE NO. 000-22320

Dear Mr. Rosenberg,

I am responding to your letter dated September 21, 2006. With respect to each of
your queries I have included the query as contained in your letter and given our
response directly below.

ITEM 5 OPERATING AND FINANCIAL REVIEW AND PROSPECTS, PAGE 18

CRITICAL ACCOUNTING POLICIES AND ESTIMATES, PAGE 19

     1.   CONSISTENT  WITH SECTION V OF FINANCIAL  REPORTING  RELEASE 72, PLEASE
          PROVIDE US THE FOLLOWING INFORMATION,  IN DISCLOSURE FORMAT ABOUT EACH
          OF THE ESTIMATES YOU HAVE DISCUSSED:

          o    THE AMOUNT OF THE CHANGE IN EACH  ESTIMATE  AND ITS EFFECT ON THE
               REVENUE  RECOGNIZED  AND/OR  PROFIT  BEFORE  TAX FOR EACH  PERIOD
               PRESENTED  OR,  THAT  CHANGES  IN  THE  ESTIMATE  HAVE  NOT  BEEN
               MATERIAL; AND,
          o    THE EFFECT OF A REASONABLY  LIKELY  CHANGE IN EACH ESTIMATE AS OF
               THE LATEST  BALANCE  SHEET DATE ON REVENUE  AND/OR  PROFIT BEFORE
               TAX.

TRINITY BIOTECH PLC RESPONSE

MANAGEMENT OF TRINITY BIOTECH PLC PROPOSES TO AMEND PROSPECTIVELY ITS
DISCLOSURES IN ITS 2006 FORM 20-F. WE HAVE INCLUDED OUR PROPOSED REVISED
DISCLOSURES BELOW:

CRITICAL ACCOUNTING POLICIES AND ESTIMATES
Our discussion and analysis of our financial condition and results of operations
are based upon our consolidated financial statements, which have been prepared
in accordance with International Financial Reporting Standards (IFRS), as
adopted by the EU. The preparation of these financial statements requires us to
make estimates and judgements that affect the reported amount of assets,
liabilities, revenues and expenses, and related disclosure of contingent assets
and liabilities.

On an on-going basis, we evaluate our estimates, including those related to
intangible assets, contingencies and litigation. We base our estimates on
historical experience and on various other assumptions that are believed to be
reasonable under the circumstances, the results of which form the basis for
making judgements about the carrying values of assets and liabilities that are
not readily apparent from other sources. Actual results may differ from these
estimates under different assumptions or conditions.

<PAGE>

We believe the critical accounting policies described below reflect our more
significant judgements and estimates used in the preparation of our consolidated
financial statements.

Research and development expenditure
Under IFRS as adopted by the EU, we write-off research and development
expenditure as incurred, with the exception of expenditure on projects whose
outcome has been assessed with reasonable certainty as to technical feasibility,
commercial viability and recovery of costs through future revenues. Such
expenditure is capitalised at cost within intangible assets and amortised over
its expected useful life of 15 years, which commences when commercial production
starts. Under US GAAP all research and development expenditure is written off to
the income statement as incurred. The impact of this treatment is reflected in
the reconciliation between IFRS, as adopted by the EU, and US GAAP contained in
Item 18, note 35 to the consolidated financial statements.

Factors which impact our judgement to capitalise certain research and
development expenditure include the degree of regulatory approval for products
and the results of any market research to determine the likely future commercial
success of products being developed. We review these factors each year to
determine whether our previous estimates as to feasibility, viability and
recovery should be changed. During 2004 and 2005 there were no changes in the
assumptions regarding the degree of regulatory approval for any of the projects
being undertaken. The Company did make changes to the estimates used to
determine the future commercial success of the projects in the normal course of
business by including updated revenue estimates. However, these changes in
revenue estimates did not result in changes in the carrying value of any of the
development costs capitalised during or prior to 2005. At December 31, 2005 the
carrying value of capitalised development costs was US$11,853,000 compared with
US$6,967,000 at December 31, 2004. The increase in 2005 was attributable to
development costs of US$4,916,000 being capitalised during 2005, the acquisition
of US$400,000 of in-process development costs as part of the Primus acquisition,
partially offset by foreign exchange movements of US$80,000 and amortisation of
US$350,000. Given the expected cash flows that will result from the successful
conclusion of the Company's on-going development projects when compared to their
respective carrying values, any reasonably possible change in estimate would not
result in a change to these carrying values. In the event that any of the
projects cannot be completed this would result in a write off of the balance in
question. The projects which are currently in progress have a range of carrying
values up to US$1,942,000.

Impairment of intangible assets and goodwill
Definite lived intangible assets are reviewed for indicators of impairment
annually while goodwill and indefinite lived assets are tested for impairment
annually, individually or at the cash generating unit level.

Factors considered important, as part of an impairment review, include the
following:

     o    Significant   underperformance  relative  to  expected  historical  or
          projected future operating results;
     o    Significant changes in the manner of our use of the acquired assets or
          the strategy for our overall business;
     o    Obsolescence of products;
     o    Significant decline in our stock price for a sustained period; and our
          market capitalisation relative to net book value.

When we determine that the carrying value of intangibles,  non-current  assets
and related  goodwill may not be recoverable  based upon the existence of one or
more of the above  indicators of  impairment,  any  impairment is measured
based on our estimates of projected net discounted cash flows expected to result
from that asset, including eventual disposition.  Our

<PAGE>

estimated impairment could prove insufficient if our analysis overestimated the
cash flows or conditions change in the future. As part of the impairment review
for 2004 and 2005, updated estimates of cash flows from sales were employed
based on the latest sales and forecast information available. These revised
estimates did not result in any impairment of intangible assets, non-current
assets or related goodwill. In the event that there was a 10% variation in the
assumed level of future growth in cashflows from sales, which would represent a
reasonably likely range of outcomes, no impairment of assets would occur in any
of the Company's cash generating units at December 31, 2004 and December 31,
2005. Similarly if there was a 10% variation in the discount rate used to
calculate the potential impairment of the carrying values, which would represent
a reasonably likely range of outcomes, no impairment of assets would occur at
December 31, 2004 and December 31, 2005.

Allowance for slow-moving and obsolete inventory
We evaluate the realisability of our inventory on a case-by-case basis and make
adjustments to our inventory provision based on our estimates of expected
losses. We write-off any inventory that is approaching its "use-by" date and for
which no further re-processing can be performed. We also consider recent trends
in revenues for various inventory items and instances where the realisable value
of inventory is likely to be less than its carrying value. Given the allowance
is calculated on the basis of the actual inventory on hand at the particular
balance sheet date, there were no material changes in estimates made during 2004
or 2005 which would have an impact on the carrying values of inventory during
those periods.

At December 31, 2005 our allowance for slow moving and obsolete inventory was
US$3,654,000 which represents approximately 9.1% of gross inventory value. This
compares with US$4,264,000, or approximately 10.2% of gross inventory value, at
December 31, 2004. The change in the estimated allowance for slow moving and
obsolete inventory as a percentage of gross inventory was due to the assessment
of the particular inventory on hand at each balance sheet date with particular
reference to the expiry dating of the inventory in question. In the event that
this estimate was to increase or decrease by 2%, of gross inventory which would
represent a reasonably likely range of outcomes, then a change in allowance of
US$802,000 at December 31, 2005 (2004: US$836,000) would result.

Allowance for impairment of receivables
We make judgements as to our ability to collect outstanding receivables and
where necessary make allowances for impairment. Such impairments are made based
upon a specific review of all significant outstanding receivables. In
determining the allowance, we analyse our historical collection experience and
current economic trends. If the historical data we use to calculate the
allowance for impairment of receivables does not reflect the future ability to
collect outstanding receivables, additional allowances for impairment of
receivables may be needed and the future results of operations could be
materially affected. Given the specific manner in which the allowance is
calculated, there were no material changes in estimates made during 2004 or 2005
which would have an impact on the carrying values of receivables in these
periods.

As disclosed in Schedule II the allowance for impairment of receivables at
December 31, 2005 was US$587,000 which represents approximately 0.6% of Group
revenues. This compares with US$462,000 at December 31, 2004 which also
represents approximately 0.6% of Group revenues. In the event that this estimate
was to increase or decrease by 0.4% of Group revenues, which would represent a
reasonably likely range of outcomes, then a change in the allowance of
US$394,000 at December 31, 2005 (2004: US$320,000) would result.

Accounting for income taxes
Significant judgement is required in determining our worldwide income tax
expense provision. In the ordinary course of a global business, there are many
transactions and calculations where the ultimate tax outcome is uncertain. Some
of these uncertainties arise as a consequence of revenue sharing and cost
reimbursement arrangements among related

<PAGE>

entities, the process of identifying items of revenue and expense that qualify
for preferential tax treatment and segregation of foreign and domestic income
and expense to avoid double taxation. Although we believe that our estimates are
reasonable, no assurance can be given that the final tax outcome of these
matters will not be different than that which is reflected in our historical
income tax provisions and accruals. Such differences could have a material
effect on our income tax provision and profit in the period in which such
determination is made. Deferred tax assets and liabilities are determined using
enacted or substantially enacted tax rates for the effects of net operating
losses and temporary differences between the book and tax bases of assets and
liabilities.

While we have considered future taxable income and ongoing prudent and feasible
tax planning strategies in assessing whether deferred tax assets can be
recognised, there is no assurance that these deferred tax assets may not be
realisable. The extent to which deferred tax assets which are recognised are not
realisable could have a material adverse impact on our income tax provision and
net income in the period in which such determination is made. In addition, we
operate within multiple taxing jurisdictions and are subject to audits in these
jurisdictions. These audits can involve complex issues that may require an
extended period of time for resolution. In management's opinion, adequate
provisions for income taxes have been made.

Note 12 to the financial statements outlines the basis for the deferred tax
assets and liabilities and Schedule II includes a movement on the valuation
allowances for income taxes during the period. There were no material changes in
estimates used to calculate the income tax expense provision during 2004 or
2005.

Warranty provision
We make judgements as to the extent to which we have to replace products which
are returned by customers due to quality issues. In determining the level of
provision required for such returns we consider our historical experience of
customers returning products. If our historical experience does / does not
reflect future levels of returned products then the level of provision is
increased / released as appropriate. Given that our historic experience in
replacing products has been infrequent and immaterial the level of warranty
provision required at December 31, 2004 and December 31, 2005 was also
determined to be immaterial. Management believes that any reasonably likely
level of returns in the future will still result in an immaterial provision
being required. However, this assessment is largely based on historic levels of
returns, which management cannot guarantee will continue to be the case and
hence in the future there may be a requirement for an increased level of
provision which could have material impact on the net assets of the Company.
There were no material changes in estimates of future levels of returns made
during 2004 or 2005.

LIQUIDITY AND CAPITAL RESOURCES, PAGE 27

WORKING CAPITAL, PAGE 28

2. PLEASE PROVIDE US, IN DISCLOSURE TYPE FORMAT, A MORE PROSPECTIVE AND ROBUST
DISCUSSION OF KNOWN DEMANDS, COMMITMENTS, TRENDS AND UNCERTAINTIES ON YOUR
LIQUIDITY AND THE EXPECTED MIX AND COST OF YOUR CAPITAL RESOURCES. EXPLAIN
FLUCTUATIONS IN CASH FLOWS FROM OPERATIONS AS REPORTED ON THE CASH FLOW
STATEMENT.

TRINITY BIOTECH PLC RESPONSE:

MANAGEMENT OF TRINITY BIOTECH PLC PROPOSES TO AMEND PROSPECTIVELY ITS
DISCLOSURES IN ITS 2006 FORM 20-F. WE HAVE INCLUDED OUR PROPOSED REVISED
DISCLOSURES BELOW:

<PAGE>

WORKING CAPITAL
In the Company's opinion the Company's existing cash position and cash generated
from operations will be sufficient to support its existing operations for at
least the next 12 months. The amount of cash generated from operations will
depend on a number of factors which include the following:
     o    The ability of the Company to continue to generate revenue growth from
          its existing product lines;
     o    The  ability of the  Company to generate  revenues  from new  products
          following the successful completion of its development projects;
     o    The extent to which  capital  expenditure  is incurred  on  additional
          property plant and equipment;
     o    The level of  investment  required to undertake  both new and existing
          development projects;
     o    Successful  working  capital  management  in the  context of a growing
          Company.
The Company expects that the cashflows that the business will generate will be
sufficient to repay the debt obligations which were outstanding at December 31,
2005. These obligations include the repayment of the remaining convertible
debentures, bank loans and finance leases. The timing of these repayment
obligations and the expected maturity dates are set out in more detail in Item
11. However, if the assumptions underlying such expectations change, the Company
may be required to raise additional capital to meet its cash require

Via Facsimile and U.S. Mail
Mail Stop 6010

                                                                                                September 21, 2006

Rory Nealon
Director/Chief Financial Officer
Trinity Biotech plc
IDA Business Park
Bray, CO. Wicklow, Ireland

Re: Trinity Biotech plc
 Form 20-F for Fiscal Year Ended December 31, 2005
 Filed March 31, 2006
 File No. 000-22320

Dear Mr. Nealon:

We have reviewed your filing and have the following comments.  We have
limited our review to only your financial stat ements and related disclosures and do not
intend to expand our review to  other portions of your documents.  In our comments, we
ask you to provide us with information so we may better understa nd your disclosure.
Please be as detailed as nece ssary in your explanation.  Afte r reviewing this information,
we may raise additional comments.

 Please understand that the purpose of our re view 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.

Item 5.  Operating And Financial Review And Prospects, page 18

Critical Accounting Policies And Estimates, page 19
1. Consistent with Section V. of Financia l Reporting Release 72, please provide us
the following information, in disclosure-type format, about each of the estimates you have discussed:

Rory Nealon
Trinity Biotech plc
September 21, 2006  Page 2
• The amount of change in each estim ate and its effect on the revenue
recognized and/or profit before tax for each period presented or, that changes
in the estimate have not been material; and,

• The effect of a reasonably likely change  in each estimate as of the latest
balance sheet date on revenue  and/or profit before tax.

Liquidity And Capital Resources, page 27

Working Capital, page 28
2. Please provide us, in disclosure type format, a more prospective and robust
discussion of known demands, commitments,  trends and uncertainties on your
liquidity and the expected mix and cost  of your capital resources.  Explain
fluctuations in cash flows from operations as reported on the cash flow statement.

*    *    *    *

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please furnish a letter that keys your responses to our comments and provide the requested information.  Detailed letters gr eatly facilitate our
review.  You should furnish the letter to  us via EDGAR under the form type label
CORRESP.

 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing include all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

 In connection with responding to our co mments, please provide, in your letter, a
statement from the company acknowledging that:

• the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

Rory Nealon
Trinity Biotech plc
September 21, 2006  Page 3
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

You may contact James Pe klenk, Staff Accountant, at (202) 551-3661, or Lisa
Vanjoske, Assistant Chief Accountant, at ( 202) 551-3614 if you have questions regarding
the comments.  In this regard, do not he sitate to contact me, at (202) 551-3679.

Sincerely,

Jim B. Rosenberg
Senior Assistant Chief Accountant

CORRESP
1
filename1.htm

Prepared and filed by St Ives Burrups

TRINITY BIOTECH PLC

IDA Business Park

Bray, Co. Wicklow

Ireland

Tel:  011 353 1 276 9800

May 20, 2005

BY FACSIMILE

Securities and Exchange Commission

450 Fifth Street, N.W.

Judiciary Plaza

Washington, D.C.  20549

Attention:  Mr. Dan Greenspan, Esq.

          Re:      Trinity Biotech plc

                      File No. 333-124385

Dear Mr. Greenspan:

     On behalf of our company, I request that the above referenced Registration Statement be declared effective by the Securities and Exchange Commission at 3:00 p.m. on May 20, 2005.                Management of our company is aware of their responsibilities under the Securities Act of 1933 as they relate to the disposition of the securities covered by the above referenced Registration Statement.  We hereby acknowledge that:

     (i)    should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

     (ii)   the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

     (iii)    the company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

     Thank you very much for your courtesy in this matter.

Very truly yours,

/s/
      Rory Nealon

    Rory
    Nealon

    Chief
    Financial Officer

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Via Facsimile and U.S. Mail
Mail Stop 3-9

						May 9, 2005

Alan J. Bernstein
Carter Ledyard & Millburn LLP
2 Wall Street
New York, New York 10005

Re:	Trinity Biotech PLC
	Registration Statement on Form F-3
	File Number 333-124385

Dear Mr. Bernstein:

	This is to advise you that we have performed a limited review
of
the above registration statement, and we have the following
comment.

      Signatures, page II-5

We note the filing does not include the signature of your
controller
or principal accounting officer.  Please include this signature in
your amended Form F-3.  See Instructions 1 and 2 to the Signatures
section of Form S-1.

*	*	*

      As appropriate, please amend your registration statement in
response to this comment.  You may wish to provide us with marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comment and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

* the company may not assert this action as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

	We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

	Please contact Daniel Greenspan at (202) 942-2974 or me at
(202)
942-1840 with any questions.

							Sincerely,

							Jeffrey P. Riedler
							Assistant Director

??

??

??

??

Alan J. Bernstein
Carter Ledyard & Millburn LLP
May 9, 2005
Page 1

</TEXT>
</DOCUMENT>