SecProbe.io

CORRESP
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filename1.htm

      Lumera
        Corporation

      19910
        North Creek Parkway

      Bothell,
        Washington 98011

      November
        22, 2005

      via
        facsimile (202-772-9218) and via EDGAR

      Securities
        and Exchange Commission

      Division
        of Corporation Finance/AD10

      100
        F
        Street, N.E.

      Washington,
        D.C. 20549-6010

      Attn:
        Timothy Buchmiller

              Re:

                Lumera
                  Corporation (the “Issuer”)

      Registration
        Statement on Form S-3, as amended (File No. 333-123973)

      Request
        for Acceleration of Effectiveness

      Ladies
        and Gentlemen:

      Pursuant
        to Rule 461 under the Securities Act of 1933, as amended, the Issuer hereby
        requests that the effective date for the Registration Statement referred
        to
        above be accelerated so that it will be declared effective at 1 p.m.
        Eastern Time, or as soon as practicable thereafter, on November 23, 2005.

      The
        Issuer acknowledges its responsibilities under the Securities Act of 1933,
        as
        amended, and the Securities Exchange Act of 1934, as amended, as they relate
        to
        the proposed public offering of the securities specified in the above-referenced
        Registration Statement. In addition, in connection with our request for
        acceleration, we acknowledge that:

                ·

                should
                  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;

                ·

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

                ·

                the
                  Issuer 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.

      Please
        call Ryan Poulson (415-315-6330) at Ropes & Gray LLP as soon as the
        Registration Statement has been declared effective.

                Very
                  truly yours,

                LUMERA
                  CORPORATION

                By:
                  /s/
                  PETER J.
                  BIERE

                Name:
                  Peter
                  J. Biere

                Title:
                  Chief
                  Financial Officer