CAL-BAY  INTERNATIONAL,  INC.

                                                               1582 PARKWAY LOOP
                                                                         SUITE G
                                                                TUSIN, CA  97280
                                                             PHONE: 714-258-7070
                                                               FAX: 714-258-7077
                                                     WWW.CALBAYINTERNATIONAL.COM
                                                     ---------------------------
                                            E-MAIL: INFO@CALBAYINTERNATIONAL.COM





November  3,  2003


Mr.  Chris  Edwards
United  States  Securities  and  Exchange  Commission
Division  of  Corporation  Finance
450  Fifth  Street,  N.W.
Washington,  DC  20549

     Re:  Cal  Bay  International,  Inc.
          SEC  File  No.  333-106562

Dear  Mr.  Edwards:

     Pursuant  to  Rule  477 of Regulation C, this letter is a formal request to
withdraw  the  SB-2  Registration Statement originally filed on June 27, 2003 by
Cal Bay International, Inc.   None of the Company's securities have been offered
or  sold.  We  are requesting withdrawal because we are re-negotiating the terms
of our Equity Line of Credit with Dutchess Private Equities Fund.  We anticipate
filing  a  new  Registration  Statement  upon  conclusion  of  the negotiations.

     Please  advise  if  you  need  any  further  information  in  order for the
Commission  to  consent  to  our request to withdraw our registration statement.


                              Very  truly  yours,


                              /s/  Robert  J.  Thompson
                              ---------------------------
                              Robert  J.  Thompson
                              President