STRASBAUGH 825 BUCKLEY ROAD SAN LUIS OBISPO, CA 93401 TELEPHONE: (805) 541-6424 November 6, 2008 Via Fax and EDGAR Correspondence - -------------------------------- Russell Mancuso Branch Chief U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Strasbaugh Form S-1/A (Amendment No. 10 to Form SB-2), Filed November 5, 2008 File No. 333-144787 Dear Sir: The undersigned, Richard Nance, in his capacity as Chief Financial Officer of Strasbaugh, a California corporation (the "Company"), hereby represents on behalf of the Company that he is not aware of any material changes to the financial results of the Company during the third fiscal quarter of 2008 as compared to the Company's financial results reported for the second fiscal quarter of 2008. Very truly yours, STRASBAUGH By: /S/ RICHARD NANCE ------------------------------- Richard Nance Chief Financial Officer