Hutchinson Technology Incorporated
40 West Highland Park Drive NE
Hutchinson, MN 55350
March 23, 2012
| Amanda Ravitz | Delivered by EDGAR |
Assistant Director
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-1
File No. 333-179384
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-1 (the “Registration Statement”) be accelerated and that such Registration Statement be declared effective at 5:00 p.m. Eastern Time on Tuesday, March 27, 2012.
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 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 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 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/ David P. Radloff |
| David P. Radloff |
| Chief Financial Officer |
| cc: | Mary Beth Breslin, Senior Counsel |
Julia Griffith, Special Counsel, Office of Mergers & Acquisitions
David M. Vander Haar
Peggy Steif Abram
Alyn Bedford
