LETTER 1 filename1.txt Mail Stop 4561 January 13, 2006 Christopher M. O`Meara Lehman Brothers Holdings Inc. Chief Financial Officer, Controller and Executive Vice President 745 Seventh Avenue New York, NY 10019 Re: Lehman Brothers Holdings Inc. Form 10-K for Fiscal Year Ended November 30, 2004 Forms 10-Q for Quarters Ended February 28, 2005, May 31, 2005 and August 31, 2005 File No. 001-09166 Dear Mr. O`Meara: We have completed our review of your Form 10-K and related filings and have no further comments at this time. Sincerely, Amit Pande Assistant Chief Accountant