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)
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.
TRANSDIGM INC.
By: /s/ Michael Lisman
Name: Michael Lisman
Title: Chief Financial Officer
Name: Michael Lisman
Title: Chief Financial Officer
cc: Michael J. Solecki, Esq.