STRASBAUGH
825 BUCKLEY ROAD
SAN LUIS OBISPO, CA 93401
TELEPHONE: (805) 541-6424
November 5, 2008
Via Fax and EDGAR Correspondence
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Russell Mancuso
Branch Chief
U.S. Securities and Exchange Commission 100 F Street, N.E.
Washington, D.C. 20549
Re: Acceleration of Effective Date
Strasbaugh
Form S-1/A (Amendment No. 10 to Form SB-2), Filed November 5, 2008
File No. 333-144787
Dear Sir:
Strasbaugh, a California corporation ("Company") hereby requests,
pursuant to Rule 461(a) of Regulation C, that the above-referenced Registration
Statement be declared effective on November 6, 2008 at 2:00 p.m. Pacific
Daylight Time, or as soon as practicable thereafter. The Company acknowledges
that:
o should the Securities and Exchange Commission ("Commission")
or the staff, acting pursuant to delegated authority, declare
the filing effective, it does not foreclose the Commission
from taking any action with respect to the filing;
o the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does
not relieve the Company from its full responsibility for the
adequacy and accuracy of the disclosure in the filing; and
o the Company may not assert 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.
Very truly yours,
STRASBAUGH
By: /S/ RICHARD NANCE
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Richard Nance
Chief Financial Officer