SecProbe.io

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Mail Stop 0306

April 28, 2005

Thomas D. Mino
Chief Executive Officer
Lumera Corporation
19910 North Creek Parkway
Bothell, Washington 98011

	Re:	Lumera Corporation
		Registration Statement on Form S-1
      	Filed on April 8, 2005
		File No. 333-123973

Dear Mr. Mino:

      This is to advise you that we have reviewed only those
portions
of your registration statement that relate to the comments below.
We
anticipate at this time that no further review of your
registration
statement and the documents incorporated by reference therein will
be
made.  Where indicated, we think you should revise your filing in
response to these comments.  If you disagree, we will consider
your
explanation as to why our comments are inapplicable or a revision
is
unnecessary.  Please be as detailed as necessary in your
explanation.
You may decide it is appropriate to provide us with supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General

1. We note that you are purporting to register for resale
1,750,000
shares of your common stock currently owned by Microvision that
may
be distributed to holders of Microvision`s outstanding senior
secured
exchangeable convertible notes.  We also note that Microvision
currently beneficially owns shares of your common stock
representing
approximately 33% of your outstanding shares, and that all of
those
shares (including the 1,750,000 shares) are being registered for
resale on Microvision`s behalf.  Please supplementally explain why
Microvision is not acting as an underwriter within the meaning of
Section 2(a)(11) of the Securities Act in connection with the
offering of those shares to the public, such that the purported
secondary offering of those shares should be instead viewed as a
primary offering by Lumera with Microvision identified as a
statutory
underwriter.
2. If you do believe that this offering is properly viewed as a
primary offering, please supplementally address the following:
* Why it is appropriate to register the completion of the offering
of
the 1,750,000 shares that may be distributed to holders of
Microvision`s outstanding notes given that a private offering of
those shares to the holders of the Microvision notes appears to
have
been commenced prior to the filing of this registration statement;
* Why the registration of that offering on Form S-1 by Lumera is
in
compliance with Rule 415(a)(1) of the Securities Act; and
* How that offering will be conducted in compliance with Rule
415(a)(4) of the Securities Act.

3. If you do not believe that this offering is properly viewed as
a
primary offering, please supplementally address the following:
* What exemption from registration under the Securities Act is or
will be available for the transfer of the 1,750,000 Lumera shares
currently held by Microvision from Microvision to the holders of
the
Microvision notes; and
* Given that the holders of the Microvision notes have the right
to
make ongoing elections to convert their notes into up to 1,750,000
shares of your common stock currently held by Microvision or into
newly issued shares of Microvision common stock, why the
registration
of the resale of those 1,750,000 shares at this time is consistent
with our guidance regarding PIPE transactions set forth in
paragraph
(b) of Telephone Interpretation No. 3S included in the Securities
Act
section of the March 1999 supplement to our Manual of Publicly
Available Telephone Interpretations.

*          *          *

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that they
have provided all information investors require for an informed
decision.  Since the company and its management are in possession
of
all facts relating to a company`s disclosure, they are responsible
for the accuracy and adequacy of the disclosures they have made.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging 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 adequacy
and
accuracy of the disclosure in the filing; 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..
	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

	We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

	If you have any questions, please call Tim Buchmiller at
(202)
824-5354 or me at (202) 942-7924.

							Sincerely,

							David Ritenour
							Special Counsel

cc:  	Christopher J. Austin, Esq.
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Thomas D. Mino
Lumera Corporation
April 28, 2005
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