Transmitted by EDGAR March 29, 2012 Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Washington, DC 20549-6010 Gentlemen: Re: Gordon & Co., 63 Pleasant Street, Suite 200, Watertown, MA 02472 File No. 333-136517 As requested by Special Counsel Sonia Barros in her letter of March 26,2010, Gordon & Co. hereby withdraws Post-Effective Amendment No. 4 to its registration on Form S-1 that was filed with the Commission on March 12, 2010 effective immediately. Very truly yours, s/ Warren G. Miller WARREN G. MILLER WGM:mlb C: Gordon & Co.