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23SER
PHOTONICS CORPORATION

1101
N. Keller Road, Suite G-2

Orlando,
FL 32810

September
23, 2024

Via
Edgar Correspondence

Jenny
O’Shanick, Esq.

Attorney
Advisor

Division
of Corporation Finance

Office
of Manufacturing

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
DC 20549

Re:
Laser Photonics Corporation

Preliminary
Information Statement on Schedule 14C

Filed
on September 17, 2024

File
No. 001-41515

Dear
Ms. O’Shanick:

Laser
Photonics Corporation (the “Company” or “Laser Photonics”) is transmitting this letter in response to
the comment received from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
by letter dated September 23, 2024, with respect to the Company’s Preliminary Information Statement on Schedule 14C. This
letter is being submitted together with the changes to the Preliminary Information Statement on Schedule 14C. The numbered paragraph
below corresponds to the numbered comment in that letter. The Staff’s comment is presented in bold italics.

Preliminary
Information Statement on Schedule 14C

General

    1.
    We
    note your disclosure on page 3 that the approval of Proposal 1 requires the “affirmative consent of a majority of the shares
    of our Common Stock issued and outstanding” as of the Record Date. We also note your other disclosure on page 6 that the approval
    of Proposal 1 requires the “affirmative vote of the holders of a majority of the votes cast.” Please revise to resolve
    this discrepancy. Further, we understand from your disclosure on page 3 that ICT Investments, LLC is the only stockholder that has
    approved Proposal 1, which “beneficially owns 8,438,695 shares of Common Stock constituting 61% of the issued and outstanding
    shares of Common Stock.” However, we note your other disclosure in the table on page 6 that ICT beneficially owns 4,438,695
    shares of Common Stock, constituting 32% of your voting power. Given that the required vote to approve Proposal 1 is a majority of
    the votes cast or outstanding shares of Common Stock, please tell us how this proposal was approved and why the company is not required
    to file a proxy statement on Schedule 14A. Please also revise to clearly disclose ICT Investments, LLC’s total voting power.

    Response:
                                            We have revised the Preliminary Information Statement on Schedule 14C to make clear that
                                            (i) the requirement for approval of Proposal 1is a majority of the issued and outstanding
                                            stock entitled to vote as of the Record Date and (ii) ICT Investments, LLC,
                                            which itself owns 32% of the voting power of the issued and outstanding shares of
                                            Laser Photonics common stock, and through its ownership and control of Fonon Corporation
                                            that owns 21.8% and Fonon Technologies, Inc. that owns 7.3%, respectively, of the issued
                                            and outstanding shares of Laser Photonics common stock, has total voting power of 61.3% of
                                            the issued and outstanding shares of Laser Photonics common stock.

If
you have any further comments or questions regarding our response, please contact our legal counsel, Ernest M. Stern, CM Law PLLC at
(301) 9102030 and by email at estern@cm.law. If you cannot reach him, please contact the undersigned at wtupuola@laserphotonics.com.

    Sincerely,

    /s/
    Wayne Tupuola

    Wayne
    Tupuola

    Cc:
    Ernest
    M. Stern, Esq.