Strasbaugh CORRESP Correspondence with SEC

Strasbaugh

825 Buckley Road

San Luis Obispo, CA 93401

September 8, 2009

Securities and Exchange Commission

Washington, D.C. 20549

Re:   Strasbaugh

Amendment No. 3 to Schedule TO

File No. 5-48009

Dear Sirs:

This is to acknowledge, on behalf of Strasbaugh, a California corporation (the “Company”), with respect to the Schedule TO filed by the Company, and all amendments thereto, that:

·  The Company is responsible for the adequacy and accuracy of the disclosure in the filing;

·  Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

·  The Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours,

/s/ Richard Nance

Richard Nance

Executive Vice President and

Chief Financial Officer