February 9, 2005

Mail Stop 03-06

Ron Sparks
President and Chief Executive Officer
Medical Device Manufacturing, Inc.
200 West 7th Avenue
Collegeville, Pennsylvania 19426-0992

Re:	Medical Device Manufacturing, Inc.
	Amendment No. 5 to Registration Statement on Form S-4
      Filed February 8, 2005
	File No. 333-118675

Dear Mr. Sparks:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General

1. We note that your most recent fiscal year ended on December 31,
2004 and that financial statements for that fiscal year are not
included (and are not, as of the date of this letter, required to
be
included) in your registration statement.  However, given the
passage
of time since the end of that year, we expect that preliminary
information is already presently known to you regarding the
company`s
financial condition as of December 31, 2004 and results of
operations
for the fiscal quarter and fiscal year then ended.  Accordingly,
please update your prospectus as appropriate to reflect any
material
changes to the company`s financial condition as of December 31,
2004
and any material changes to the company`s results of operations
that
occurred during the fourth quarter of the company`s 2004 fiscal
year.
If there are no such material changes to report, please
supplementally provide a representation to that effect in response
to
this comment.

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      You may contact Heather Tress at (202) 824-5263 or Kate
Tillan
at (202) 942-2861 if you have questions regarding comments on the
financial statements and related matters. Please contact Donald C.
Hunt at (202) 824-5662 or me at (202) 942-7924 with any other
questions.


      Sincerely,



							David Ritenour
							Special Counsel


cc:	Christopher J. Walsh, Esq. (via fax)
	Scott A. Berdan, Esq. (via fax)


Mr. Ron Sparks
Medical Device Manufacturing, Inc.
February 9, 2005
Page 1