Blue Holdings, Inc.
5804 E. Slauson Ave.
Commerce, California 90040

October 18, 2005

Securities and Exchange Commission
450 Fifth Street, N.W.
Judiciary Plaza
Washington, DC 20549

                  Re:      Blue Holdings, Inc.
                           Registration Statement on Form SB-2
                           Registration Number:  333-128906

Ladies and Gentlemen:

Blue  Holdings,  Inc.  (the  "Company")  hereby  respectfully  requests that the
Company's  Registration  Statement on Form SB-2 (Registration Number 333-128906)
(the  "Registration  Statement") be withdrawn as of the date hereof  pursuant to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  private offering in reliance on Rule 155(c)  promulgated
under the Securities  Act of 1933, as amended.  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/ Patrick Chow
-------------------------------------------
By:   Patrick Chow
Its:  Chief Financial Officer and Secretary