June 27, 2007 Via U.S. Mail and Facsimile (650-940-4710) Barry G. Caldwell President, Chief Executive Officer, and Director Iridex Corporation 1212 Terra Bella Avenue Mountain View, CA 94043-1824 Re: Iridex Corporation Form 10-K for the Fiscal Year Ended December 31, 2005 Filed April 3, 2006 Form 10-Q for the Quarterly Period Ended July 1, 2006 Filed December 22, 2006 Form 10-K for the Fiscal Year Ended December 30, 2006 Filed March 30, 2007 File No. 0-27598 Dear Mr. Caldwell: We have reviewed your response letter dated April 30, 2007 and we have the following comments. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. General 1. We note your response to comment 1 in our letter dated March 30, 2007. You state in your letters dated February 28, 2007 and April 30, 2007 that you have sold the OcuLight SL/SLx Infrared (810 nm) solid-state laser into Iran, Sudan, and Syria. Certain solid- state lasers are on the Commerce Control List ("CCL") maintained by the Commerce Department`s Bureau of Industry and Security, and thus are controlled items to which the Export Administration Regulations apply. Please clarify for us whether your OcuLight SL/SLx laser falls within the scope of the CCL and, if so, discuss for us your compliance with U.S. export laws. 2. You state on page 34 of your Form 10-K for the fiscal year ended December 30, 2006 that certain of your products were distributed in Iran without U.S. governmental authorization. Please describe for us the products so distributed; the circumstances of the unauthorized distribution(s); how you became aware of the unauthorized distribution(s); any steps you have taken or will take to address this matter with appropriate government authorities; potential fines and penalties resulting from the unauthorized distribution(s); and the potential impact of the matter, including any fines and penalties, upon your reputation and financial condition. * * * * * Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please file your response letter on EDGAR. Please understand that we may have additional comments after we review your response to our comments. Please contact Pradip Bhaumik, Attorney-Advisor, at (202) 551-3333 if you have any questions about the comments or our review. You may also contact me at (202) 551- 3470. Sincerely, Cecilia D. Blye, Chief Office of Global Security Risk cc: Peggy Fisher Assistant Director Division of Corporation Finance Barry G. Caldwell Iridex Corporation June 27, 2007 Page 2