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CORRESP
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corresp

Bookham, Inc.

2584 Junction Avenue

San Jose, California 95134

October 7, 2005

By EDGAR and Facsimile

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Attention:

    Dennis Hult, Staff Accountant

    Eduardo Aleman, Staff Attorney

    Re:

    Bookham, Inc.

    Registration Statement on Form S-3

    File No. 333-127546

    Request for Acceleration

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Bookham, Inc. (the
“Registrant”) hereby requests acceleration of the effective date of the above-referenced
registration statement (the “Registration Statement”), so
that it may become effective at 4:00
p.m., Eastern time, on October 11, 2005, or as soon thereafter as practicable.

The Registrant hereby acknowledges that:

    (i)

    should the Securities and Exchange Commission (the “Commission”) or the staff,
acting pursuant to delegated authority, declare the Registration Statement effective,
it does not foreclose the Commission from taking any action with respect to the
Registration Statement;

    (ii)

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

    (iii)

    the Registrant may not assert the action of the Commission or the staff,
acting pursuant to delegated authority, in declaring the Registration Statement
effective as a defense in any proceeding initiated by the Commission or any person
under the federal securities laws of the United States.

If you require any additional information, please do not hesitate to contact me at 613-270-4050 or
Douglas Barry of Wilmer Cutler Pickering Hale and Dorr LLP at 617-526-6501.

    Sincerely,

BOOKHAM, INC.

    By:
    /s/ Thomas Kelley

    Thomas Kelley

    General Counsel