January 23, 2013
VIA EDGAR AND FACSIMILE
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Mail Stop 4561
Washington, D.C. 20549
Attention: Tim Buchmiller, Reviewing Attorney
Re: Wright Medical Group, Inc. Registration Statement on Form S-4 File No. 333-185601
Acceleration Request
| Requested Date: | January 23, 2013 | |
| Requested Time: | 1:00 p.m., Eastern Time |
Ladies and Gentlemen:
In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Wright Medical Group, Inc. (the “Registrant”) hereby requests that the above-referenced Registration Statement on Form S-4 (No. 333-185601) (the “Registration Statement”) be declared effective on the “Requested Date” and at the “Requested Time” set forth above or as soon thereafter as practicable or at such later time as the Registrant or its counsel may orally request via telephone call to the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”). Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Wilson Sonsini Goodrich & Rosati, by calling Martin Waters or Robert Kornegay at 858-350-2300.
In connection with the acceleration request, the Registrant hereby acknowledges that:
| • | should 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; |
| • | 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 |
| • | the Registrant may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Respectfully submitted, |
Wright Medical Group, Inc. |
/s/ James A. Lightman |
Senior Vice President, General Counsel and Secretary |
