Mail Stop 6010


      January 6, 2006


Mr.  David D. Harrison
Chief Financial Officer
Pentair, Inc.
5500 Wayzata Boulevard, Suite 800
Golden Valley, Minnesota  55416

	Re:	Pentair, Inc.
      Form 10-K for the Year Ended December 31, 2004
Forms 10-Q for the Quarter Ended March 31, 2005, June 30, 2005,
and
     September 30, 2005
      File No. 000-04689

Dear Mr. Harrison:

	We have completed our review of your Form 10-K and related
materials and do not, at this time, have any further comments.


	 							Sincerely,



								Martin F. James
								Senior Assistant Chief
Accountant




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