- Withdrawal of Registration Statement (RW)

Blue Holdings, Inc.

4901 Zambrano Street

 Commerce, CA 90040

 

March 11, 2009

Securities and Exchange Commission

Division of Corporation Finance

Washington, DC 20549

Re.:

Registration Statement on Form S-8 Registration No. 333-147873

 

Ladies and Gentlemen:

The undersigned hereby requests the withdrawal of its registration statement on Form S-8 (Registration  No.333-147873). None of the securities registered in that registration statement have been issued or sold.

 

Very truly yours,   /s/ Paul Guez Paul Guez Chairman