SecProbe.io

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      March 28, 2005

Mail Stop 0409 via U.S. Mail and Fax (770) 246-7941

Mr. Morris E. Van Asperen
Chief Financial Officer
Color Imaging, Inc
4350 Peachtree Industrial Blvd. Suite 100
Norcross, GA 30071

Re:	Color Imaging, Inc
	Form 10-K for the year ended December 31, 2004
      File No. 000-18450

Dear Mr. Van Asperen:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and will make no further review of your
documents.  As such, all persons who are responsible for the
adequacy
and accuracy of the disclosure are urged to be certain that they
have
included all information required pursuant to the Securities
Exchange
Act of 1934.

      Where indicated, we think you should revise your document in
response to these comments.  If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Item 9 A. Controls and Procedures, Page 53
1. We note your statement that a "control system, no matter how
well
conceived and operated, can provide only reasonable, not absolute,
assurance that the objectives of the internal control system are
met."  Please revise to state clearly, if true, that your
disclosure
controls and procedures are designed to provide reasonable
assurance
of achieving their objectives and that your principal executive
officer and principal financial officer concluded that your
disclosure controls and procedures are effective at that
reasonable
assurance level.  In the alternative, remove the reference to the
level of assurance of your disclosure controls and procedures.
Please refer to Section II.F.4 of Management`s Reports on Internal
Control Over Financial Reporting and Certification of Disclosure
in
Exchange Act Periodic Reports, SEC Release No. 33-8238, available
on
our website at http://www.sec.gov/rules/final/33-8238.htm.
2. You also state that "Further, the design of a control system
must
reflect the fact that there are resource constraints, and the
benefits of controls must be considered relative to their costs.
Because of the inherent limitations in all control system, no
evaluation of controls can provide absolute assurance that all
control issues and instances of fraud, if any, within the Company
have been detected.  These inherent limitations include the
realities
that judgments in decision-making can be faulty, and that
breakdown
can occur because of simple error or mistake. The design of any
system of controls also is based in part upon certain assumptions
about the likelihood of future events, and there can be no
assurance
that any design will succeed in achieving its stated goals under
all
potential future conditions." Pursuant to Section II.F.4 of
Management`s Reports on Internal Control Over Financial Reporting
and
Certification of Disclosure in Exchange Act Periodic Reports, SEC
Release No. 33-8238, if management decides to include a discussion
of
reasonable assurance, the discussion must be presented in a manner
that does not make the disclosure in the report confusing.  Your
statements regarding "no assurance" appear to contradict your
discussion of reasonable assurance.  Please explain or revise
accordingly.
3. We note your disclosure that your management "concluded that
our
disclosure controls and procedures were effective in timely
alerting
them to material information relating to Color imaging required to
be
included in our periodic SEC filings." Please revise to clarify,
if
true, that your officers concluded that your disclosure controls
and
procedures are effective to ensure that information required to be
disclosed in the reports that you file under the Exchange Act is
recorded, processed, summarized and reported within the time
periods
specified in the Commission`s rules and procedures.  Please also
revise to clarify, if true, that your officers concluded that your
disclosure controls and procedures are also effective to ensure
that
information required to be disclosed in these reports is
accumulated
and communicated to your management, including your chief
executive
officer and chief financial officer, to allow timely decisions
regarding required disclosure.  Refer to Exchange Act Rule 13a-
5(e).
4. We note your statement that "Although we concluded that our
disclosures controls and procedures were effective at the end of
fiscal 2004 and in each interim period of fiscal 2004, we
recognized
that further improvements could be made with regard to purchasing
and
receiving.  During 2004 the improvements made to our internal
controls included:  the updating of our policies for disclosure
controls and financial reporting and the commencement of the
updating
of the procedures and tests to be implemented during 2005 in
compliance with SOX 404." Please provide appropriate disclosure
explaining how the disclosure controls and procedures were
determined
to be effective in light of the identified matters.
5. In consideration of the above comments, please revise your
discussion of your controls in the Risk Factors section on page 15
and 16 of your filing.

*    *    *    *

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please file your cover
letter
on EDGAR.  Please understand that we may have additional comments
after reviewing your amendment and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.

      You may contact Thomas Flinn, Staff Accountant, at (202)
842-
5225 or the undersigned at (202) 942-1975 if you have questions.

						Sincerely,

Cicely D. Luckey
Senior Staff Accountant

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Color Imaging, Inc.
March 28, 2005
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