TransDigm Group INC — Capital/Financing Update 2020

May 12, 2020

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May 12, 2020

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549

Attention: Anne Nguyen Parker, Manufacturing Branch Chief, Martin James,

Manufacturing Senior Advisor and Sergio Chinos, Staff Attorney

Re: TransDigm Inc. Registration Statement on Form S-4 (Registration No. 333-238018)

Ladies and Gentlemen:

On behalf of TransDigm Inc. and the other registrants named in the Registration Statement on Form S-4 (File No. 333-238018) (together, “ TransDigm ”), the undersigned hereby requests, pursuant to Rule 461(a) promulgated under the Securities Act of 1933, that the Registration Statement on Form S-4 (File No. 333-238018) of TransDigm be declared effective at 3:00 p.m. on Thursday, May 14, 2020, 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, TRANSDIGM INC.

By: /s/ Michael Lisman Name: Michael Lisman Title: Chief Financial Officer

cc: Michael J. Solecki, Esq.