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April 8, 2010

VIA EDGAR

Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549

Re:  Thermo Fisher Scientific Inc.
Registration Statement on Form S-4
File No. 333-165173
Request for Acceleration

Ladies and Gentlemen:

     Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Thermo Fisher Scientific Inc. (the “Registrant”) hereby requests acceleration of the effective date of its Registration Statement on Form S-4 (File No. 333-165173), as amended (the “Registration Statement”), so that it may become effective at 12:00 p.m. on April 12, 2010, or as soon thereafter as practicable.

     The Registrant hereby acknowledges that:

(i)	should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;
(ii)	the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and
(iii)	the Registrant may not assert the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours, Thermo Fisher Scientific Inc.
By:	/s/ Seth H. Hoogasian
	Seth H. Hoogasian
	Senior Vice President, General Counsel and Secretary

81 Wyman Street	Waltham, MA	(781) 622-1000	www.thermofisher.com
Post Office Box 9046	02454-9046	(781) 622-1207 fax