[LETTERHEAD OF HOLT'S CIGAR COMPANY]
November 21, 1997
United States Securities and
Exchange Commission
Attn: Jennifer Hardy, Esq.
450 Fifth Street
Washington, D.C. 20549
RE: Holt's Cigar Holdings, Inc.
Registration Statement on Form S-1 (Registration No. 333-36263)
Registration Statement on Form 8-A filed on November 20, 1997
Dear Ms. Hardy:
This correspondence shall constitute a request by the captioned registrant
for withdrawal of the Registration Statement on Form 8-A filed by Holt's Cigar
Holdings, Inc. on Thursday, November 20, 1997. Simultaneously herewith Holt's
Cigar Holdings, Inc. is filing by EDGAR a replacement Form 8-A.
In accordance with the request for acceleration submitted by the registrant
on November 20, 1997, Holt's Cigar Holdings, Inc. confirms that it respectfully
requests that the replacement Form 8-A filed herewith be declared effective
pursuant to Section 12(g) of the Securities Act of 1934, as amended,
concurrently with its Registration Statement on Form S-1 under the Securities
Act of 1934, as amended, at 2:00 p.m. on Monday, November 24, 1997, or as soon
thereafter as possible.
Very truly yours,
HOLT'S CIGAR HOLDINGS, INC.
By: /s/ Michael Pitkow
-----------------------------
Michael Pitkow
Executive Vice President
