Lehman Brothers

December 8, 2006

Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

Re:	IPG Photonics Corporation
	Registration Statement on Form S-1 (File No. 333-136521)

Ladies and Gentlemen:

     As underwriters of the Company’s proposed public offering of up to 10,350,000 shares of common stock, we hereby join the Company’s request for acceleration of the above-referenced Registration Statement, requesting effectiveness for 4:00 p.m. (NYT) on December 12, 2006, or as soon thereafter as is practicable.

     Pursuant to Rule 460 of the General Rules and Regulations under the Securities Act of 1933, we wish to advise you that we have effected the following distribution of the Company’s Preliminary Prospectus dated November 27, 2006, through the date hereof:

     Preliminary Prospectus dated November 27, 2006:

     14,044 copies to prospective Underwriters, institutional investors, dealers and others

     The undersigned advise that they have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934.

Very truly yours,
LEHMAN BROTHERS INC.
MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED
As Representatives of the several Underwriters
By:	LEHMAN BROTHERS INC.
By:	/s/ Victoria Hale
	Victoria Hale
	Vice President