[LOCATEPLUS HOLDINGS CORPORATION LETTERHEAD]

October 19,2006

Via  Edgar

Securities  and  Exchange  Commission
Division  of  Corporation  Finance
Mail Stop 4561
Washington,  D.C.  20549

Attention:  Mark P. Shuman

  Re:     LocatePLUS  Holdings  Corporation
          Registration  Statement  on  Form  SB-2
          SEC  File  No  333-132585

Dear  Mr. Shuman:

     Pursuant  to  Rule  477(a) promulgated under the Securities Act of 1933, as
amended  (the  "Securities  Act"),  LocatePLUS  Holdings  Corporation  (the
"Registrant")  hereby  respectfully  requests  that  the Securities and Exchange
Commission  consent to the withdrawal of its Registration Statement on Form SB-2
(File No. 333-132585)  originally filed  on  March 20, 2006, together with all
amendments  and  exhibits  thereto (collectively, the "Registration Statement").
The  Registration  Statement  covered  the  resale  of  certain  shares  of  the
Registrant's  Common Stock by  the Registrant's stockholders.  The Registration
Statement has not been  declared effective and no  shares of Common Stock of the
Registrant have been or will be resold pursuant to the  Registration  Statement.

     The  Registrant  further  requests  that, pursuant to Rule 477(c), an order
with  the date of the granting of the withdrawal be included in the file for the
aforementioned  Registration  Statement in the following manner: "Withdrawn upon
the  request  of  the  Registrant,  the  Commission  consenting  thereto."

     Please  forward  copies  of  the  order consenting to the withdrawal of the
Registration  Statement  to  the  undersigned  at 100 Cummings Center Ste. 235M,
Beverly,  MA 01915.  If you have any questions  regarding  this  request, please
call  Mr.  Fields  at  (978) 921-2727.  Thank  you  for your assistance.

Very  truly  yours,

LocatePLUS  Holdings  Corporation

By:  /s/  Jon  R.  Latorella
     -----------------------
      Jon  R.  Latorella
      President  and  Chief  Executive  Officer