SecProbe.io

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                         LUMINENT MORTGAGE CAPITAL, INC.
                909 Montgomery Street, Suite 500, San Francisco, CA 94133
         415-486-2110 Main -- 877-486-2110 Toll Free -- 415 486-2111 Fax
                             www.luminentcapital.com

January 19, 2005

VIA FACSIMILE AND EDGAR

Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549-0306

            RE:   ACCELERATION REQUEST BY LUMINENT MORTGAGE CAPITAL, INC.
                  REGARDING AMENDMENT NO. 1 TO REGISTRATION STATEMENT ON FORM
                  S-3 (REGISTRATION STATEMENT NO. 333-121816) (THE "REGISTRATION
                  STATEMENT")

Ladies and Gentlemen:

      Pursuant to Rule 461 under the Securities Act of 1933, as amended, the
undersigned hereby requests that the effective date for the Registration
Statement be accelerated so that the Registration Statement may become effective
at 4:00 p.m. (Washington, D.C. time) on January 21, 2005, or as soon thereafter
as practicable.

      In addition, in connection with our request for acceleration of the
effective date of the Registration Statement, the undersigned 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 undersigned
from its full responsibility for the adequacy and accuracy of the disclosure in
the Registration Statement; and (iii) the undersigned may not assert this action
as a defense in any proceeding initiated by the Commission or any person under
the federal securities laws of the United States.

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January 19, 2005 - Page 2

      Please contact our securities counsel, Frederick W. Dreher, Esq. of Duane
Morris LLP, at (215) 979-1234 to confirm the effectiveness of the Registration
Statement or to communicate any questions you might have regarding this letter
or the Registration Statement.

         Thank you.

                                         Very truly yours,

                                         LUMINENT MORTGAGE CAPITAL, INC.

                                         By      /s/ CHRISTOPHER J. ZYDA
                                           -------------------------------------
                                             Christopher J. Zyda
                                             Senior Vice President and
                                             Chief Financial Officer

cc:      Frederick W. Dreher, Esq.

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