1 Earth and Ocean Sports, Inc. 70 Airport Road Hyannis, MA 02601 March 17, 1998 Securities and Exchange Commission 450 Fifth Street, N.W. Washington, DC 20549 Attention: Ms. Goldie Walker RE: Earth and Ocean Sports, Inc. Registration Statement on Form S-1 File No. 333-24089 Ladies and Gentleman: Pursuant to Rule 477 promulgated under the Securities Act of 1933, as amended, Earth and Ocean Sports, Inc. (the "Company") hereby requests that its Registration Statement referred to above relating to the underwritten public offering of shares of its common stock, $.01 par value per share, be withdrawn, effective immediately due to continuing adverse market conditions and consistent with the public interest and the protection of investors. No sales of the Company's securities were made under the above referenced Registration Statement. EARTH AND OCEAN SPORTS, INC. By: /S/ MINNIE P. JOUNG --------------------- Name: Minnie P. Joung Title: Secretary Enclosure cc: Edwin L. Miller, Jr. Jon Anthony Glydon