June 4, 2007 VIA EDGAR - --------- United States Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: SUPERIOR GALLERIES, INC. AMENDMENT NO. 2 TO FORM SB-2 FILE NO. 333-124196 FILED MAY 29, 2007 Dear Sir or Madam: Pursuant to Rule 477 promulgated under the Securities Act of 1933, as amended, Superior Galleries, Inc., a Delaware corporation, respectfully requests that the Securities and Exchange Commission (the "COMMISSION") consent to the withdrawal of the above-referenced Amendment No. 2 to Form SB-2 to the Registration Statement on Form SB-2 (the "POST-EFFECTIVE AMENDMENT") because the Amendment was submitted with the wrong EDGAR code (coded as a Pre-Effective Amendment) requiring a revised filing. Please do not hesitate to contact the undersigned at (972) 484-3662 or Richard Marr of Rutan & Tucker LLP at (714) 662-4652 should you have any questions with respect to this request. Very truly yours, /S/ John Benson ------------------------------- John Benson Interim Chief Financial Officer