Mail Stop 3561


October 12, 2005


Colin M. Angle
iRobot Corporation
63 South Avenue
Burlington, Massachusetts 01803

      	Re:	iRobot Corporation
      		Amendment No. 2 to Form S-1
      		File No. 333-126907
      		Filed September 30, 2005

Dear Mr. Angle:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.  Please note that the page numbers mentioned in our
comments refer to those used in the marked courtesy copies of the
amendment.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  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.


* * * * *

1. We have considered your response to prior comment 1 of our
September 23, 2005 letter.  The reasons for including "iRobot User
Comments" in your prospectus are unclear, as the testimonials seem
to
be geared more for marketing your products than conveying balanced
information about the company or the offering.  Please delete this
page, or revise it to provide balanced information about the
company,
its products or the offering.  To the extent you continue to
include
user comments, please provide us, with your next response letter,
with consents from the quoted customers and end-users to being
cited
in the prospectus.  Also tell us whether any of the quoted
customers
and end-users were paid for their testimonials or endorsements.
If
so, then disclose the fact that they were paid.

Management`s Discussion and Analysis
Critical Accounting Policies and Estimates
Accounting for Stock Based Awards, page 34
2. Regarding the stock option grants, we remind you to provide a
discussion in the MD&A of each significant factor contributing to
the
difference between the fair value as of the date of each grant and
the estimated IPO price.

Note 10-Stock Option Plan, page F-18
3. For each stock option grant date subsequent to July 2, 2005,
please tell us the number of options or shares granted, the
exercise
price, the fair value of the common stock, and the intrinsic
value,
if any per option (the number of options may be aggregated by
month
or quarter and the information presented as weighted average per-
share amounts).


* * * * *


      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Joseph Cascarano at (202) 551-3376 or Robert
Littlepage at (202) 551-3361 if you have questions regarding
comments
on the financial statements and related matters.  Please contact
Ted
Yu at (202) 551-3372, Kathleen Krebs, Special Counsel, at (202)
551-
3350, or me at (202) 551-3810 with any other questions.


Sincerely,



Larry Spirgel
Assistant Director



cc:	Edward A. King, Esq.
	Goodwin Proctor LLP
	Via Facsimile: (617) 523-1231

??

??

??

??

Colin M. Angle
iRobot Corporation
October 12, 2005
Page 1