Baltic International USA, Inc. 1990 Post Oak Boulevard, Suite 1630 Houston, Texas 77056-3813 Telephone: (713) 961-9299	 Fax: (713) 961-9298 May 29, 1998 Filing Desk Securities and Exchange Commission 450 Fifth Street, NW Washington, DC 20549 Re:	Baltic International USA, Inc. 	Post-Effective Amendment No. 1 to Registration Statement on Form SB-2 	Filed December 22, 1997 	(File No. 333-860) Ladies & Gentlemen: On behalf of Baltic International USA, Inc. (the "Company") and in connection with the Company's filing of Post-Effective Amendment No. 1 to its Registration Statement on Form SB-2, initially filed with the Securities and Exchange Commission on June 13, 1996, please note that, effective immediately, we are withdrawing such Registration Statement. The Company intends to file a new Registration Statement on Form SB-2 that will also serve as the Post-Effective Amendment No. 1 to the Registration Statement No. 333-860. Please provide the Company and the Company's legal counsel, Norman T. Reynolds, Looper, Reed, Mark and McGraw, L.L.P., 1300 Post Oak, Suite 200, Houston, Texas 77056, with a copy of the order granting withdrawal of the Registration Statement as soon as it is available. If you have any questions regarding this application, please do not hesitate to contact Mr. Reynolds at (713) 651-0244 or the undersigned at (713) 961-9299. Very truly yours, /s/ David A. Grossman David A. Grossman Chief Financial Officer and Corporate Secretary