[GRAPHIC OMITTED]
                                    VISUALANT
                 Suite 406, 500 Union Street, Seattle, WA 98101
                    Telephone: 206 903.1351 Fax: 206 903.1352


                                November 16, 2005



U.S. Securities and Exchange Commission
450 Fifth Street N.W.
Washington, D.C.  20549
Attention:  John Fieldsend

Re:      Visualant, Incorporated
         Registration Statement on Form SB-2
         File No.  333-127100
         SB-2/A filed on November 10, 2005


Dear Mr. Fieldsend:

Pursuant to Rule 477(a) of the  Securities  Act of 1933, as amended,  Visualant,
Incorporated  hereby requests that Amendment No. 2 to its Form SB-2 Registration
Statement  (File No.  333-127100)  filed with the SEC on November 10,  2005,  be
withdrawn.

This  Amendment is being  withdrawn  for the reason that an  additional  200,000
shares were incorrectly included as part of that Amendment. The Company confirms
that no securities have been issued or sold pursuant to that Amendment.


                                                     Sincerely,

                                                   /s/ Ralph M. Brier
                                                   --------------------------
                                                       Ralph M. Brier
                                                       President and CEO