[Letterhead of Schulte Roth & Zabel LLP]

(212) 756-2153                                          edward.schauder@srz.com

                                December 2, 2004


Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549

Attention:    Brigitte Lippmann

              "REGISTRATION STATEMENT") FILE NO. 333-118750

Dear Ms. Lippmann:

       On behalf of BlueLinx Holdings Inc. (the "REGISTRANT"), and in
anticipation of requesting acceleration of the effective date of the
Registration Statement on or about December 13, 2004, the Registrant
acknowledges that:

       o      Should the Securities and Exchange Commission (the "COMMISSION")
              or the Staff, acting pursuant to delegated authority, declare the
              filing effective, the Registrant does not foreclose the Commission
              from taking any action with respect to the filing;

       o      the action of the Commission or the Staff, acting pursuant to
              delegated authority, in declaring the filing effective, does not
              relieve the Registrant from its full responsibility for the
              adequacy and accuracy of the disclosure in the filing; and

Securities and Exchange Commission
December 2, 2004
Page 2

       o      the Registrant may not assert this action as a defense in any
              proceeding initiated by the Commission or any person under the
              federal securities laws of the United States.

       Thank you for your continued attention to and expeditious review of our

                                                 Very truly yours,

                                                /s/ Edward H. Schauder
                                                Edward H. Schauder, Esq.

CC:    Barbara V. Tinsley
       BlueLinx Holdings Inc.
       General Counsel and Secretary

       David J. Morris
       BlueLinx Holdings Inc.
       Chief Financial Officer

       Michael R. Littenberg, Esq.
       Schulte Roth & Zabel LLP