INTEGRA LIFESCIENCES HOLDINGS CORPORATION
                              311 ENTERPRISE DRIVE
                          PLAINSBORO, NEW JERSEY 08536

July 31, 2006


CONFIDENTIAL

VIA EDGAR
Ms. Celeste M. Murphy, Esq.
U.S.  Securities and Exchange  Commission
Special Counsel
Office of Mergers and Acquisitions
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549

                  Re:    Integra LifeSciences Holdings Corporation Schedule
                         TO-I filed
                         July 17, 2006
                         (File No. 005-45421)
                         --------------------

Dear Ms. Murphy:

         Pursuant to your letter dated July 27, 2006, we acknowledge that:

         |X|      the Company is  responsible  for the  adequacy and accuracy of
                  the disclosure in the filings;

         |X|      Staff  comments or changes to  disclosure in response to Staff
                  comments in the filings reviewed by the Staff do not foreclose
                  the  Commission  from  taking any action  with  respect to the
                  filing; and

         |X|      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  addition,   we  acknowledge  that  the  Commission's   Division  of
Enforcement  has access to all  information  that we may provide to the Staff of
the Commission's Division of Corporation Finance in its review of our filings or
in response to its comments on our filing.

         Should you have any  questions  relating  to  foregoing,  please do not
hesitate to contact the  undersigned  at (609)  275-0500 or Peter M. Labonski of
Latham & Watkins LLP at (212) 906-1323.  Thank you for your cooperation and your
attention in this matter.


                                                    Very Truly Yours,

                                                    /s/ MAUREEN B. BELLANTONI
                                                    ----------------------------
                                                    Maureen B. Bellantoni
                                                    Executive Vice President and
                                                    Chief Financial Officer



cc:      Latham & Watkins LLP