May 12, 2020

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549

Attention:     Anne Nguyen Parker, Manufacturing Branch Chief, Martin James,

Manufacturing Senior Advisor and Sergio Chinos, Staff Attorney

Re: TransDigm Inc.Registration Statement on Form S-4 (Registration No. 333-238018)

Ladies and Gentlemen:

On behalf of TransDigm Inc. and the other registrants named in the Registration Statement on Form S-4 (File No. 333-238018) (together, “TransDigm”), the undersigned hereby requests, pursuant to Rule 461(a) promulgated under the Securities Act of 1933, that the Registration Statement on Form S-4 (File No. 333-238018) of TransDigm be declared effective at 3:00 p.m. on Thursday, May 14, 2020, or as soon thereafter as practicable. TransDigm respectfully requests that you notify Michael J. Solecki of such effectiveness by a telephone call to (216) 586-7103.

Please contact Michael J. Solecki of Jones Day at (216) 586-7103 if you have any questions concerning this matter. Thank you for your continued attention to this matter.

Very truly yours,
TRANSDIGM INC.

By: /s/ Michael Lisman        Name:     Michael Lisman    Title:    Chief Financial Officer

cc:    Michael J. Solecki, Esq.