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.






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.