TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo May 11, 2020 Kevin M. Stein President TransDigm Group Inc. 1301 East 9th Street, Suite 300 Cleveland, Ohio 44114 Re: TransDigm Group Inc. Registration Statement on Form S-4 Filed May 5, 2020 File No. 333-238018 Dear Mr. Stein: 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 Sergio Chinos, Staff Attorney, at (202) 551-7844 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Michael J. Solecki