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[Foster Wheeler Ltd. Letterhead]

June 22, 2005

VIA FACSIMILE
AND EDGAR

Securities and
Exchange Commission

Judiciary Plaza

450 5th Street, N.W.

Washington, DC  20549

Attention:  Ms. Dorine Miller

Re:                             Foster
Wheeler Ltd.

Registration Statement on Form S-3 (File No. 333-125223)

Ladies and Gentlemen:

Pursuant to Rule 461
under the Securities Act of 1933, Foster Wheeler Ltd., a Bermuda company (the “Company”),
hereby requests acceleration of the effective date of its Registration
Statement on Form S-3 (File No. 333-125223) to 10:00 a.m.,
Washington, D.C. time, on Monday, June 27, 2005, or as soon thereafter as
practicable.

In addition, we hereby
acknowledge that:

•                  Should the
Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action
with respect to the filing;

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

•                  The Company many
not assert this action as defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United States.

Please call the
undersigned at (908) 730-4000 or John J. Kelley of King &
Spalding LLP at (404) 572-3401 if you have any questions.

  FOSTER WHEELER
  LTD.

  By:

    /s/
  John T. La Duc

  John T. La Duc

  Executive
  Vice President and Chief

  Financial Officer

  cc:

  John J. Kelley

  King &
  Spalding LLP

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