October 3, 2007



Mr. Jay Webb
United States Securities and Exchange Commission
Washington, D.C. 20549


             Re:  Excel Technology, Inc
                  Form 10-K for the year ended December 31, 2006
                  Filed February 20, 2007
                  File No. 000-19306


Dear Mr. Webb:

We are in receipt of your letter dated September 19, 2007 regarding some
follow up questions from our first response.

Terminated Merger Costs
........................

Excel Technology, Inc. classified the terminated merger costs as non-
operating.  Although there is no accounting guidance that prescribes the
income statement geography of merger expenses, we believed that since
these costs were not related to the Company's ongoing, major or central
operations, that they should be classified as non-operating.  This
definition of operating costs was identified in an SEC comment letter
received by another SEC registrant.  That letter defined operating costs
as those that related to the Company's ongoing, major or central
operations.  The legal fees were directly related to Coherent's attempt
to purchase our Company and Coherent's regulatory filings (US DOJ and
German FCO) that were required to execute the transaction.  These costs
were classified as non-operating costs since they were expenses outside
the Company's main operating activities of selling merchandise or
providing services.  None of the above costs would have been incurred if
Coherent had not attempted to acquire us and therefore were classified
as non-operating.

Excel Technology also acknowledges the following:

          - The company is responsible for the adequacy and accuracy of
            the disclosure in the filings;
          - 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.

If you have any questions, please call me at (631) 784-6188.

                              Sincerely,

                              /s/  Alice Varisano
                              .......................
                              Alice Varisano
                              Chief Financial Officer