(212) 701-3380

May 4, 2007

Re:

TriMas Corporation:
Form S-1 filed August 3, 2006
File No 333-136263

Dear Ms. Long:

On behalf of TriMas Corporation (“Trimas” or the “Company”), the Company files herewith, via EDGAR, Amendment No. 6 to its Registration Statement on Form S-1 (“Amendment No. 6”) filed with the Commission on August 3, 2006 (the “Registration Statement”). This amendment sets forth the Company’s responses to the Staff’s comments contained in its letter dated May 3, 2007 relating to the Registration Statement. Four unmarked copies of Amendment No. 6 to the Form S-1 and copies that are marked to show changes from Amendment No. 5 to the Form S-1, along with three copies of this letter are to be hand delivered to you, for the Staff’s convenience.

Set forth below, for the convenience of the Staff, are the Staff’s comments contained in your letter and immediately below each comment is the Company’s response. Unless otherwise noted, all page references in the Staff’s comments are to Amendment No. 5 and page references in the Company’s responses are to Amendment No. 6.

Dilution, page 25

1. Please provide us with your calculation of tangible net assets both before and after the
transaction.

Response: The Company sets forth below its calculation of tangible net assets both before and after the transaction.

As of March 31, 2007
($ in thousands, except share amounts)

	As of March 31, 2007
	Actual			Pro forma
Total Assets	$	1,300,150		$		1,301,000

Less: Goodwill	(529,130		)	(529,130				)

Other intangibles, net	(236,550		)	(236,550				)

Deferred debt issue costs (a)	(13,870		)	(11,520				)

	$	520,600		$			523,800

Total Liabilities	(1,060,830		)	(953,840				)

Net Tangible Book Value	$	(540,230	)	$	(430,040			)

Weighted average shares outstanding	20,759,000			31,759,500

Net Tangible Book Value/Share	$	(26.02	)	$	(13.54			)	$	12.48

(a) Classified as Other assets in the consolidated balance sheet.

Unaudited Pro Forma Financial Information, page 27

2. Please disclose in a footnote, separately by type of security, the number of shares not included in arriving at pro forma diluted EPS for each period because they were anti-dilutive.

Response: The Company has revised its disclosure on pages 28 to 30 of the prospectus in response to the Staff’s comment.

3. As noted on page 27, please tell us where you included the expected loss of approximately $7.6 million on extinguishment of debt in the adjustments to your pro forma balance sheet. Otherwise, please revise your pro forma balance sheet and footnote disclosures accordingly.

	Very truly yours,


	/s/Jonathan A. Schaffzin
	Jonathan A. Schaffzin