August 14, 2019
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549
Anne Nguyen Parker, Assistant Director, Office of Transportation and Leisure
Registration Statement on FormS-4 (RegistrationNo. 333-233103)
Ladies and Gentlemen:
On behalf of TransDigm Inc. and the other registrants named in the Registration Statement on FormS-4 (FileNo. 333-233103) (together, “TransDigm”), the undersigned hereby requests, pursuant to Rule 461(a) promulgated under the Securities Act of 1933, that the Registration Statement on FormS-4 (FileNo. 333-233103) of TransDigm be declared effective at 2:00 p.m. on Friday, August 16, 2019, 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,
/s/ Michael J. Lisman
|Name: Michael J. Lisman|
|Title: Chief Financial Officer|
cc: Michael J. Solecki, Esq.