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[Morrison & Foerster LLP Letterhead]

September 6, 2005

Via EDGAR and Facsimile

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Room 4561

Washington, D.C. 20549

    Attention:

    Adam Halper

Facsimile: (202) 772-9210

    Re:

    MTI Technology Corporation.

Preliminary Proxy Statement

Filed August 26, 2005

File No. 000-23418

Ladies and Gentlemen:

On behalf of our client, MTI Technology Corporation (the “Company”), attached are copies of
communications I submitted to the Staff on August 30, 2005 and August 31, 2005, respectively, in
response to oral comments of the Staff regarding the above-referenced filing (the “Proxy
Statement”), which were conveyed by Adam Halper of the Staff to Tamara P. Tate of our firm on
August 30, 2005.

Per my conversations with Mr. Halper, and consistent with the attached communications, the Company
has: (i) incorporated by reference into the definitive version of the Proxy Statement, which was
filed today, its Annual Report on Form 10-K (which was filed on July 18, 2005); and (ii) deleted references in Proposal 1 of the Proxy Statement to
certain other documents being incorporated by reference to a previously-filed Form 8-K (the Company
has instead included each of those documents in an appendix to the Proxy Statement).

September 6, 2005

Page Two

If you would like to discuss this or any other matter with respect to the Company, please contact
the undersigned at the number listed above or Ms. Tate at (949) 251-7148.

    Very truly yours,

    /s/ John T. Mitchell

    John T. Mitchell

Enclosures

    cc:

    Thomas P. Raimondi (w/o enclosures)

Tamara P. Tate, Esq. (w/o enclosures)

[Morrison & Foerster LLP Letterhead]

To:

                Name:

    Facsimile:

    Telephone:

    Adam Halper

Division of Corporation Finance

U.S. Securities and Exchange

Commission

    (202)772-9210

    (202) 551-3482

              Morrison & Foerster Office:

    Tamara Tate, Orange County

    From: John T. Mitchell

    Date: August 30, 2005

                Number of pages

with cover page:

    3

    Originals Will Not Follow

Preparer of this slip has confirmed that facsimile number given is correct: 8880/jtm6

CAUTION — CONFIDENTIAL

This facsimile contains confidential information that may also be privileged. Unless you
are the addressee (or authorized to receive for the addressee), you may not copy, use, or
distribute it. If you have received it in error, please advise Morrison & Foerster LLP
immediately by telephone or facsimile and return it promptly by mail.

Comments:

Adam – Thanks for taking a look at this. Please let me know if this does
not resolve your concerns regarding the MTI Technology Corporation
preliminary proxy statement that was filed with the SEC on August 26, 2005.
If it does, we’ll revise the proxy statement as you discussed with Tamara
Tate earlier today. Feel free to call me at (949) 251-7527 if you would
like to discuss.

[To be inserted immediately prior to the signature block on page 38 of the preliminary proxy
statement of MTI Technology Corporation that was filed with the SEC on August 26, 2005.]

Rider 38A

ADDITIONAL INFORMATION

     We are a reporting company and file annual, quarterly and current reports, proxy statements
and other information with the SEC. You may read and copy these reports, proxy statements and other
information at the SEC’s public reference rooms. You can request copies of these documents by
writing to the SEC and paying a fee for the copying costs. Please call the SEC at 1-800-SEC-0330
for more information about the operation of the public reference rooms. Our SEC filings are also
available at the SEC’s website at www.sec.gov and in the Investor Relations section of our website
at www.mti.com/co/ir.asp.

INCORPORATION OF CERTAIN DOCUMENTS BY REFERENCE

     We file annual, quarterly and current reports, proxy statements and other information with the
SEC. The SEC allows us to “incorporate by reference” the information we file with it, which means
that we can disclose important information to you by referring you to those documents. We are
incorporating our Annual Report on Form 10-K for the year ended April 2, 2005, which was filed with
the SEC on July 18, 2005, as amended by our Form 10-K/A, filed on August 1, 2005, into this proxy
statement by reference. The information incorporated by reference into this proxy statement is an
important part of this proxy statement.

     A copy of our 2005 Annual Report on Form 10-K, as amended, has been mailed with this proxy
statement. Copies are also available free of charge at our website and the SEC’s website, as
noted above under “Additional Information,” as well as upon request to our Investor Relations
department, at MTI Technology Corporation, 14661 Franklin Avenue, Tustin, California 92780, (714)
481-7800.

[Morrison & Foerster LLP Letterhead]

To:

                Name:

    Facsimile:

    Telephone:

    Adam Halper

Division of Corporation Finance

U.S. Securities and Exchange

Commission

    (202)772-9210

    (202) 551-3482

              Morrison & Foerster Office:

    Tamara Tate, Orange County

    From: John T. Mitchell

    Date: August 31, 2005

Number
of pages
with cover page:

    3

    Originals Will Not Follow

Preparer of this slip has confirmed that facsimile number given is correct: 8880/jtm6

CAUTION — CONFIDENTIAL

This facsimile contains confidential information that may also be privileged. Unless you
are the addressee (or authorized to receive for the addressee), you may not copy, use, or
distribute it. If you have received it in error, please advise Morrison & Foerster LLP
immediately by telephone or facsimile and return it promptly by mail.

Comments:

Adam – Thanks for looking at this revised language. Please let me know if
this suffices. If it does, I’ll proceed with preparing the EDGAR
correspondence and the definitive proxy statement as we discussed. Feel
free to call me at (949) 251-7527 if you would like to discuss.

[To be inserted immediately prior to the signature block on page 38 of the preliminary proxy
statement of MTI Technology Corporation that was filed with the SEC on August 26, 2005.]

Rider 38A

ADDITIONAL INFORMATION

     We are a reporting company and file annual, quarterly and current reports, proxy statements
and other information with the SEC. You may read and copy these reports, proxy statements and other
information at the SEC’s public reference rooms. You can request copies of these documents by
writing to the SEC and paying a fee for the copying costs. Please call the SEC at 1-800-SEC-0330
for more information about the operation of the public reference rooms. Our SEC filings are also
available at the SEC’s website at www.sec.gov and in the Investor Relations section of our website
at www.mti.com/co/ir.asp.

INCORPORATION OF CERTAIN DOCUMENTS BY REFERENCE

     We file annual, quarterly and current reports, proxy statements and other information with the
SEC. The SEC allows us to “incorporate by reference” the information we file with it, which means
that we can disclose important information to you by referring you to those documents. The
information incorporated by reference into this proxy statement is an important part of this proxy
statement. Specifically, we are incorporating the following documents by reference into this proxy
statement:

    •

    our Annual Report on Form 10-K for the year ended April 2, 2005, which was
filed with the SEC on July 18, 2005, as amended by our Form 10-K/A, filed on
August 1, 2005; and

    •

    the Securities Purchase Agreement (including the forms of Warrants and Amended
and Restated Investor Rights Agreement, which are exhibits to and included with
the Securities Purchase Agreement), which has been filed as Exhibit 10.1 to our
Current Report on Form 8-K that was filed with the SEC on August 22, 2005.

     A copy of our 2005 Annual Report on Form 10-K, as amended, has been mailed with this proxy
statement. We will provide, free of charge, to each person to whom a proxy statement is delivered,
a copy of any and all of the information that has been incorporated into this proxy statement by
reference, upon written or oral request (and by first class mail or other equally prompt means
within one business day of receiving the request) to our Investor Relations department, at MTI
Technology Corporation, 14661 Franklin Avenue, Tustin, California 92780, (714) 481-7800. Copies of
those documents are also available free of charge at our website and the SEC’s website, as noted
above under “Additional Information.”