TDGTransDigm Group

We note you have properties and operations in various geographic areas and countries. We further note you have not provided the entity-wide disclosures contemplated in ASC 280-10-50-41. Please modify your segment disclosures in future filings to provide these additional disclosures or otherwise please explain why you believe they are not required.

Rest of the question

For additional guidance, please also refer to ASC 280-10-55-20 through 55-25. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

We acknowledge the Staff's comment and the standards set forth in ASC 280-10-50-41 and related guidance. In future filings, the Company will disclose net sales to external customers and long-lived assets attributable to the United States separately from other geographic areas. The geographic areas in which net sales and long-lived assets will be disclosed are "United States" and "Foreign Countries," with net sales being based on the geographic destination of sales.

Rest of the answer

Net sales and long-lived assets of individual countries outside of the United States are not material.

If you have any further questions or require additional information, please do not hesitate to contact me at (216) 706-2960.

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