Hutchinson Technology Incorporated
40 West Highland Park Drive NE
Hutchinson, MN 55350
July 13, 2011
| Amanda Ravitz | Delivered by EDGAR | |||
| Assistant Director | and Email | |||
| U.S. Securities and Exchange Commission | ||||
| Division of Corporation Finance | ||||
| 100 F. Street, N.E. | ||||
| Washington, D.C. 20549 |
| Re: | Hutchinson Technology Incorporated |
Registration Statement on Form S-4
File No. 333-173970
Dear Ms. Ravitz:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, Hutchinson Technology Incorporated (the “Company”), hereby respectfully requests that the effective date of the above-referenced Registration Statement on Form S-4 (the “Registration Statement”) be accelerated and that such Registration Statement be declared effective at 5:00 p.m. Eastern Time on Friday, July 15, 2011.
In connection with its request for acceleration, the Company acknowledges its responsibilities under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended, and the rules and regulations thereunder, as they relate to the Registration Statement. The Company also acknowledges that:
| • | should the Commission or the Staff, acting pursuant to delegated authority, declare the Registration Statement Amendment effective, it does not foreclose the Commission from taking any action with respect to the filing; |
| • | the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement Amendment effective, does not relieve us from our full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
| • | the Company may not assert Staff comments and the declaration of effectiveness of the Registration Statement Amendment 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, |
/s/ Wayne M. Fortun |
| Wayne M. Fortun |
| Chief Executive Officer |
| cc: | Joseph McCann, Senior Counsel |
David Orlic, Special Counsel, Office of Mergers & Acquisitions
David P. Radloff
Peggy Steif Abram
