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March 18, 2005

Mr. Martin James
Senior Assistant Chief Accountant
United States Securities and Exchange Commission
Mail Stop 0306
Washington, D.C.  20549

Re:     Optical Communication Products, Inc.
        Form 10-K for the year ended September 30, 2004

Dear Mr. James:

We address the following comments made in your correspondence dated January 28,
2005:

Form 10-K for the year ended September 30, 2004
-----------------------------------------------

Item 7.  Management's Discussion and Analysis of Financial Condition and Results
--------------------------------------------------------------------------------
of Operations
-------------

Results of Operations - Page 36
-------------------------------

1.      In future filings, consider presenting a tabular comparison of your
        results in different periods, with percentage changes, followed by your
        narrative discussion and analysis of the reasons for material changes
        and their implications. Refer to SEC Release No. 34-48960.

        We acknowledge your comment to consider presenting a tabular comparison
        of our results of operations in different periods, with percentage
        changes, followed by our narrative discussion and analysis of the
        reasons for material changes and their implications. In future filings,
        we will present such a table, as well as a discussion of the reasons for
        material changes and, to the extent we are able to determine them, their
        implications.

2.      Please refer to Item 303(A) of Regulation S-K and FRR No. 36-501.4 and
        revise the discussion in future filings to address the following:

                      Optical Communication Products, Inc.
                               6101 Variel Avenue
                        Woodland Hills, California 91367

<PAGE>

        (a)    Discuss and quantify the extent to which the increases or
               decreases in net revenue are attributable to price changes,
               volume changes, the introduction of new products, etc.

               We believe your comment refers to increases or decreases in
               "revenue" (rather than "net revenue"). We will endeavor to
               discuss and quantify the significant increases or decreases in
               revenue that are attributable to such factors as price changes,
               volume changes, and the introduction of new products.

        (b)    Identify and quantify the contributing factors when two or more
               items contribute to the material change in a line item. For
               example, instead of merely stating the increase was due to an
               increase in demand from your existing customers, or an increase
               in sales to other customers; explain the underlying reasons for
               the increase and any offsetting decreases.

               We acknowledge your comment to identify and quantify the
               contributing factors when two or more items contribute to the
               material change in a line item and will expand explanations and
               discussions in future filings, to the extent we are able to make
               such determinations, to separately quantify and discuss such
               changes.

               Consider utilizing a tabular presentation to show the percentage
               changes between periods for MAN, LAN and SAN sales and provide a
               textual explanation of those changes.

               We acknowledge your comment about utilizing a tabular
               presentation to show the percentage changes between periods for
               MAN, LAN and SAN sales and providing a textual explanation of
               those changes. We will include such a table and discussion in
               future filings.

        (c)    Discuss the substantial increases in your gross profit percentage
               in 2003 and 2004. Tell investors how you were able to achieve
               these increases and, to the extent possible, disclose what
               management anticipates in the future.

               In future filings, we will include a discussion of substantial
               increases in our gross profit (including how we achieved these
               results) and, to the extent we are able to reach a conclusion
               regarding the future, what management anticipates. Because the
               market in which we operate has been volatile, however,
               anticipating future increases or decreases in gross profit may
               not be possible.

3.      Revise your discussion in future filings to also address specific
        Research & Development projects or groups of related projects.

                      Optical Communication Products, Inc.
                               6101 Variel Avenue
                        Woodland Hills, California 91367

<PAGE>

        (a)    To the extent possible, disclose the costs incurred to date, the
               current status, and the estimated completion dates, completion
               costs and capital requirements.

        (b)    If estimated completion dates and costs are not reasonably
               certain, discuss those uncertainties.

        (c)    Disclose the risks and uncertainties associated with completing
               development projects on schedule and the consequences if they are
               not completed timely.

        (d)    Discuss your expected long-term plan for Research & Development
               expenditures.

        We respectfully advise the staff that we have endeavored to disclose as
        much information as possible regarding our research and development
        programs without compromising our competitive position.

        Specifically with respect to your comment 3(c), we note that our past
        filings have included specific risk factors that highlight the risks and
        uncertainties associated with, and the consequences of failing to
        accomplish, timely completion of our development projects. (See, e.g.,
        our risk factor entitled "The market for our products is new and is
        characterized by rapid technological changes and evolving industry
        standards. If we do not respond to the changes in a timely manner, our
        products likely will not achieve market acceptance.") With respect to
        future filings, we will review and update, as appropriate, our risk
        factors with respect to research and development to make them as
        relevant as possible to our current circumstances.

4.      In addition, we note the significant increase in research and
        development costs in 2003 as compared to 2002. Where changes in
        financial statement line items are significant and the result of several
        factors, each significant factor should be separately quantified and
        discussed. For example, you say that the increase "was due to an
        increase in salaries and other operating costs resulting from the
        increase on personnel and operation costs associated with the
        acquisitions of certain business assets of Cielo Communications and Gore
        Photonics and the addition of engineering personnel hired." However, you
        do not quantify the impact of each of these factors. Refer to SEC
        Release No. 34-48960.

        We acknowledge your comment that, where changes in financial statement
        line items are significant and the result of several factors, each
        significant factor should be separately quantified and discussed.
        Consistent with our response to Item 2, we will endeavor to separately
        quantify and discuss such changes in future filings.

5.      We note your explanation for the decrease in general and administrative
        expenses in fiscal 2004 as compared to fiscal 2003 as well as the
        increase in fiscal 2003 as compared to 2002. Specifically you explain
        that the decrease in 2004 is in part related

                      Optical Communication Products, Inc.
                               6101 Variel Avenue
                        Woodland Hills, California 91367

<PAGE>

        to a decrease in insurance expense primarily related to a decrease in
        directors' and officers' insurance premiums. In contrast, you explain
        the increase in 2003 as compared to 2002 is due in part to an increase
        in insurance expense primarily related to an increase in directors' and
        officers' insurance premiums.

        (a)    In future filings discuss the reasons for the fluctuations in
               your premium expense and to the extent that this represents a
               trend, then tell investors.

               We acknowledge your comment and will discuss in future filings
               the reasons for fluctuations in our insurance premium expense. To
               the extent such changes represent a trend and we are able to
               identify it as such, we will also include in future filings a
               statement in that regard.

        (b)    If the 2003 increases represented a one-time event, for example -
               a catch-up payment, then you should also highlight that fact for
               investors.

               We acknowledge your comment and will indicate in future filings
               if any such significant increase or decrease is a one-time event.
               The increase in 2003 was not a catch-up payment.

Consolidated Balance Sheet - Page F-3
-------------------------------------

6.      We note that other accrued expenses represent approximately 26% of total
        current liabilities. In future filings, please state separately, in the
        balance sheet or in a note, any item, included in accrued liabilities,
        which is in excess of 5 percent of total current liabilities in
        accordance with Regulation S-X Article 5-02(20).

        We acknowledge your comment and, in future filings, we will state
        separately any items included in accrued liabilities that are in excess
        of 5 percent of current total liabilities in accordance with Regulation
        S-X Article 5-02(20).

Note 1.  Significant Accounting Policies
----------------------------------------

Inventories - Page F-8
----------------------

7.      We note that the company has repeatedly utilized inventory in production
        that was previously written down as excess inventory. In future filings
        and in a supplemental response please address the following:

        (a)    Expand your accounting policy for inventory obsolescence to
               include how the company accounts for usage of such inventory.

               At the point of write down, a new, lower-cost basis for that
               inventory is established, and subsequent changes in facts and
               circumstances do not result in the restoration or increase in
               that newly established cost basis. On occasion, we have
               discovered that written-down

                      Optical Communication Products, Inc.
                               6101 Variel Avenue
                        Woodland Hills, California 91367

<PAGE>

               inventory was not obsolete or excess, as previously estimated. In
               those situations, the written down inventory is sold and
               reflected in cost of sales at the new written-down basis. Future
               filings will include this expanded discussion of our policy for
               inventory obsolescence.

        (b)    Disclose your methods and timing for scrapping obsolete inventory
               and describe the circumstances which have resulted in your
               utilizing material amounts of obsolete inventory in the reported
               periods.

               We estimate our excess and obsolete inventory primarily through
               reference to historical usage and future demand forecasts. We
               operate in a highly-volatile industry with high and unpredictable
               rates of inventory obsolescence. We do not necessarily scrap
               written-down inventory; and if we receive purchase orders from
               our customers for products which use the previously written-down
               inventories, we will utilize these inventories to produce and
               fill those orders.

               During fiscal year ended September 30, 2001, the
               telecommunications industry, and in particular the fiber optic
               networking sector, suffered a severe downturn. As a result of our
               customers' declining business and the resulting adjustment of
               their inventory levels, we recorded an extraordinarily large
               write down of excess inventory of $18.1 million. Since fiscal
               year 2001, our write down of excess inventory has returned to a
               more reasonable level. Our write down of inventory for fiscal
               year 2004 was $759,000. Also, as demand from our customers
               increased after fiscal year 2001, we were able to utilize
               material amounts of inventory that had previously been written
               down.

               Please also see our response to Item 7(a) above. We respectfully
               advise the staff that we do not believe that our methods and
               timing for scrapping obsolete inventory and the circumstances
               which have resulted in our utilizing material amounts of obsolete
               inventory in the reported periods are appropriate footnote
               disclosures. We do, however, agree that such information is
               appropriate in MD&A and will make such disclosure in future
               filings.

        (c)    Expand your critical accounting policy discussion in MD&A
               relating to inventory write-downs to provide similar disclosure.

               We acknowledge your comment and will expand our critical
               accounting policy in MD&A relating to inventory write-downs to
               provide similar disclosure.

Revenue Recognition - Page F-8
------------------------------

8.      We note that you sell your products to communication equipment
        manufacturers and through contract manufacturers.

                      Optical Communication Products, Inc.
                               6101 Variel Avenue
                        Woodland Hills, California 91367

<PAGE>

        (a)    Tell us and expand your revenue recognition policy to explain how
               you account for price concessions offered to customers.

               Price concessions are recorded as an offset to revenue, but price
               concessions are not a material part of our business. For example,
               in fiscal 2004, we provided a provision of $19,945 for price
               protection; the actual cost was zero in fiscal 2004. If price
               concessions become a material part of our business, we will
               expand our revenue recognition policy in future filings to
               explain how we account for such price concessions offered to
               customers.

        (b)    Tell us whether any of your product sales include price
               protection agreements or any obligations to buy back inventory
               from computer equipment manufacturers or contract manufacturers.

               Price protection and inventory buy back programs are not a
               material part of our business. For example, the total reserve for
               this exposure from these programs in fiscal 2004 was $79,309; the
               actual cost was zero in fiscal 2004. These costs are included in