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Bausch & Lomb
Incorporated

One Bausch &
Lomb Place

Rochester, New
York 14604

December 6, 2004

Securities and Exchange
Commission

Division of Corporation
Finance

450 Fifth Street, N.W.

Judiciary Plaza

Washington, DC 20549

  Attn.

  Mr. Eduardo Aleman

  Ms. Celeste M. Murphy

  Re:

  Bausch & Lomb
  Incorporated.

  Registration Statement
  on Form S-4 (Registration No. 333-120483)

  Related filing:
  Schedule TO-I (File No. 005-20467)

Ladies and Gentlemen:

In accordance with Rule 461 of Regulation C
promulgated under the  Securities Act of
1933, as amended, Bausch & Lomb Incorporated hereby requests acceleration
of the effectiveness of the above-captioned Registration Statement to
become effective on Thursday, December 9, 2003 at 9:00 a.m., or as soon as
practicable thereafter.

In connection with this request for acceleration and
as requested in the comment letter from the staff, dated November 24, 2004, the
company acknowledges that:

- if the Securities and
Exchange Commission or its staff, acting pursuant to delegated authority,
declares the filing of the Registration Statement on Form S-4 (No. 333-120483)
effective, such action does not preclude the Commission from taking any action
with respect to the filing;

- the action by the
Commission or its staff, acting pursuant to delegated authority, in declaring
the filing effective, does not relieve the company from its full responsibility
for the adequacy and accuracy of the disclosure in the filing; and

- the company may not
assert this action as a defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United States.

Securities
and Exchange Commission

December
6, 2004

Please call me or
our counsel, Deborah McLean Quinn at Nixon Peabody LLP, 585-263-1307 with any
questions or comments.

  Very truly yours,

  BAUSCH & LOMB
  INCORPORATED

  /s/ Efrain
  Rivera

  By:  Efrain Rivera

  Vice President and
  Treasurer

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