[Letterhead of Inter-Tel, Incorporated]

April 27, 2006

United States Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549

Re:	Inter-Tel, Incorporated
	Preliminary Proxy Statement on Schedule 14A
	Filed April 18, 2006
	File No. 0-10211

     Ladies and Gentlemen:

     As requested by the staff in comment letter dated April 21, 2006, and with regard to the filing of revised preliminary proxy material as of the date hereof, Inter-Tel, Incorporated (the “Company”) hereby acknowledges to the United States Securities and Exchange Commission (the “Commission”) that:

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

• Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking 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,

INTER-TEL, INCORPORATED

By   /s/ Kurt R. Kneip                
Name: Kurt R. Kneip
Title: Chief Financial Officer
and Senior Vice President