Baltic International USA, Inc.
1990 Post Oak Boulevard, Suite 1630
Houston, Texas 77056-3813
Telephone: (713) 961-9299 Fax: (713) 961-9298
June 2, 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 has sold no shares from
the filing of such Registration Statement on December 22, 1997 until the date
of this letter. The Company has filed a new Registration Statement on Form SB-
2 on June 1, 1998 that will also serve as the Post-Effective Amendment No. 1 to
the Registration Statement No. 333-860. The Company determined that it would
be administratively better to file a new Registration Statement to incorporate
in one document the registration of securities issued from date of the
effectiveness of the Form SB-2 on June 13, 1996 until today and to update the
Prospectus for the securities registered on June 13, 1996 rather than to have
two separate registration statements.
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