Blue
Holdings, Inc.
5804 East
Slauson Avenue
Commerce,
California 90040
February
19, 2008
Securities
and Exchange Commission
Division
of Corporation Finance
100 F.
Street, N.E.
Washington,
DC 20549
Registration
Statement on Form S-3
Registration
Number: 333-149024
Ladies
and Gentlemen:
Blue
Holdings, Inc. (the “Company”) hereby respectfully requests that the Company’s
Registration Statement on Form S-3 (Registration Number 333-149024) (the
“Registration Statement”) be withdrawn as of the date hereof pursuant to Rule
477 promulgated under the Securities Act of 1933, as amended. The
Company’s request is based on the fact that the Company has determined not to
pursue the proposed offering as described in the Registration
Statement. The Company may undertake a subsequent primary offering on
Form S-3 as permitted by the general instructions of such form. The
Registration Statement was never declared effective and no securities of the
Company were sold pursuant thereto.
If you
have questions regarding this matter, please contact the undersigned at
323-725-5555.
Respectfully,
BLUE
HOLDINGS, INC.
|
/s/ Larry Jacobs
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|
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By: Larry
Jacobs
|
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Its: Chief
Financial Officer
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