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SEC Company Response from FINISAR CORP (CIK 0001094739) — Jun 14, 2005

FINISAR CORP (CIK 0001094739)
Date: June 14, 2005 · CIK: 0001094739 · Accession: 0000891618-05-000427

AI Filing Summary & Sentiment

File numbers found in text: 333-125034

Date
June 14, 2005
Author
FINISAR CORPORATION
Form
CORRESP
Company
FINISAR CORP (CIK 0001094739)

Letter

Securities and Exchange Commission Attention: Mr. Tim Buchmiller Re: Finisar Corporation, a Delaware Corporation (the “Company”) Registration Statement on Form S-1 (Registration No. 333-125034)

Dear Mr. Buchmiller:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), the Company hereby requests that the effectiveness of the above-referenced registration statement be accelerated to 5:00 p.m., Eastern Time, on Tuesday, June 14, 2005, or as soon thereafter as practicable.

The Company hereby acknowledges that:

•

should the Commission or the Staff, acting pursuant to delegated authority, declare the registration statement effective, the Commission is not foreclosed from taking any action with respect to the registration statement;

•

the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the registration statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the registration statement; and

•

the Company may not assert Staff comments and the declaration of effectiveness 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

June 14, 2005

Page Two

Thank you for your assistance. If you should have any questions, please contact Joe C. Sorenson of DLA Piper Rudnick Gray Cary US LLP, counsel to the Company, at (650) 833-2282.

Very truly yours,
FINISAR CORPORATION

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CORRESP
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corresp

FINISAR CORPORATION

1308 Moffett Park Drive

Sunnyvale, California 94089

VIA FACSIMILE (202-942-9585) AND EDGAR

June 14, 2005

Securities and Exchange Commission

Mail Stop 03-06

450 Fifth Street, N.W.

Washington, D.C. 20549-1004

Attention: Mr. Tim Buchmiller

    Re:

    Finisar Corporation, a Delaware Corporation (the “Company”)

    Registration Statement on Form S-1 (Registration No. 333-125034)

Dear Mr. Buchmiller:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), the Company hereby
requests that the effectiveness of the above-referenced registration statement be accelerated to
5:00 p.m., Eastern Time, on Tuesday, June 14, 2005, or as soon thereafter as practicable.

The Company hereby acknowledges that:

      •

    should the Commission or the Staff, acting pursuant to delegated authority, declare the
registration statement effective, the Commission is not foreclosed from taking any action
with respect to the registration statement;

      •

    the action of the Commission or the Staff, acting pursuant to delegated authority, in
declaring the registration statement effective, does not relieve the Company from its full
responsibility for the adequacy and accuracy of the disclosure in the registration
statement; and

      •

    the Company may not assert Staff comments and the declaration of effectiveness 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

June 14, 2005

Page Two

Thank you for your assistance. If you should have any questions, please contact Joe C. Sorenson of
DLA Piper Rudnick Gray Cary US LLP, counsel to the Company, at (650) 833-2282.

Very truly yours,

FINISAR CORPORATION

    By:

    /s/ Stephen K. Workman

    Stephen K. Workman

    Senior Vice President, Finance

    and Chief Financial Officer

    cc:

    Dennis C. Sullivan, Esq.

    Joe C. Sorenson, Esq.