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                            ARNALL GOLDEN GREGORY LLP
                               171 17TH STREET NW
                                   SUITE 2100
                           ATLANTA, GEORGIA 30363-1031

                                                      Direct phone: 404.873.8706
                                                        Direct fax: 404.873.8707
                                                      E-mail: Robert.Dow@agg.com
                                                                     www.agg.com

                                 March 31, 2005

VIA EDGAR

Ms. Cicely D. Luckey
Senior Staff Accountant
Division of Corporation Finance
U.S. Securities and Exchange Commission
450 Fifth Street, NW
Washington, D.C. 20549-0305

         RE:      COLOR IMAGING, INC.
                  FORM 10-K FOR YEAR ENDED DECEMBER 31, 2004
                  FILE NO. 00-18450

Dear Mr. Mancuso:

     On behalf of our client, Color Imaging, Inc. ("Color Imaging"), we transmit
Color Imaging's  response to the Staff's letter of comment dated March 28, 2005.
For your convenience,  the comments contained in that letter are reprinted below
in italics.  We have  enclosed a draft of revised  Item 9A and the risk  factor,
marked to show changes to respond to your comments.

     Color Imaging's responses are as follows:

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  Report 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.

     RESPONSE:

     We have added language to state clearly that we are giving assurance at the
     "reasonable assurance" level.

2.   You also state that "Further, the design of 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

<PAGE>

Ms. Cicely D. Luckey
March 31, 2005
Page 2

     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  Certifications  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.

     RESPONSE:

     We  have  revised  the  disclosure  to  remove  the "no  assurance"  phrase
     throughout.

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).

     RESPONSE:

     We have added the language you suggested in your comment.

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.

     RESPONSE:

     We have added  disclosure  to indicate  that the  disclosure  controls were
     effective  even prior to these changes.  The disclosure  indicates that the
     changes are enhancements but did not materially change internal control.

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.

     We have  revised  the risk  factor to remove all use of the "no  assurance"
     language. We also disclose that although controls were effective,  there is
     a risk related to the lack of completion of the SOX 404 process.

<PAGE>

Ms. Cicely D. Luckey
March 31, 2005
Page 2

     In addition,  the Company has  authorized me to  acknowledge on its behalf,
that the  Company is  responsible  for the  adequacy  of the  disclosure  in its
filings;  staff  comments or changes to disclosure in response to staff comments
do not  foreclose  the  Commission  form 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.

     If you agree that these changes are  responsive to your  comments,  we will
amend the Form 10-K to reflect the  changes.  Please  contact us to give us your
feedback.  If you have any  questions,  please do not  hesitate to contact me at
(404) 873-8706 or T. Clark Fitzgerald III at (404) 873-8622.

                                       Very truly yours,

                                       ARNALL GOLDEN GREGORY LLP

                                       /s/ Robert F. Dow
                                       Robert F. Dow

cc:     Thomas Flinn
        Morris E. Van Asperen, Chief Financial Officer
        T. Clark Fitzgerald III, Esq.

<PAGE>

     Note:  This  Amendment  No. 1 on Form  10-K/A is filed for the  purpose  of
clarifying the disclosure contained at Item 9A of the Annual Report for the year
ending  December 31, 2004,  concerning the  conclusions  of the Company's  Chief
Executive Officer and its Chief Financial Officer that the Company's  disclosure
control and procedures are effective at the reasonable  assurance  level as more
particularly described below in this Amendment No. 1.

ITEM 9A. CONTROLS AND PROCEDURES

EVALUATION OF DISCLOSURE CONTROLS AND PROCEDURES

We maintain  disclosure controls and procedures that are designed to ensure that
information  required to be  disclosed  on our Exchange Act reports is recorded,
processed,  summarized  and reported  within the time  periods  specified in the
Commission's  rules and forms,  and that such  information  is  accumulated  and
communicated to our management,  including our Chief Executive Officer and Chief
Financial Officer, as appropriate,  to allow timely decisions regarding required
disclosure.

The  Company's  management  does not expect that its  disclosure  controls  will
prevent all error and all fraud. A control system,  no matter how well conceived
and operated,  can provide only  reasonable,  not absolute,  assurance  that the
objectives  of the  control  system  are met.  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 systems,  an evaluation of controls may not
detect all control  issues and instances of fraud,  if any,  within the Company.
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.  The design may
not succeed in achieving its stated goals under all potential future conditions.
The Company has,  however,  designed its  disclosure  controls and procedures to
provide,  and believes that such controls and procedures do provide,  reasonable
assurance  that  information  required to be disclosed by the Company in reports
that it files or submits under the Securities  Exchange Act of 1934 is recorded,
processed,  summarized  and reported  within the time  periods  specified in the
SEC's  rules  and  forms.  The  disclosure  in  this  paragraph  about  inherent
limitations of control  systems does not modify the conclusions set forth in the
next paragraph of the Company's Chief Executive  Officer and its Chief Financial
Officer  concerning the effectiveness of the Company's  disclosure  controls and
procedures.

As of the end of the period  covered by this  report,  December  31,  2004, , we
carried out an evaluation,  under the supervision and with the  participation of
Color  Imaging's  management,  including our Chief  Executive  Officer and Chief
Financial  Officer,  of the  effectiveness  of the design and operation of Color
Imaging's  disclosure controls and procedures.  Based upon this evaluation,  the
Chief  Executive   Officer  and  Chief  Financial  Officer  concluded  that  our
disclosure  controls and procedures  were effective at the reasonable  assurance
level to ensure that  information  required to be  disclosed on our Exchange Act
reports is recorded, processed,  summarized and reported within the time periods
specified in the  Commission's  rules and forms,  and that such  information  is
accumulated and  communicated  to our management,  including our Chief Executive
Officer and Chief Financial Officer,  as appropriate,  to allow timely decisions
regarding required disclosure.

CHANGES  IN  DISCLOSURE  CONTROLS  AND  PROCEDURES  AND  INTERNAL  CONTROL  OVER
FINANCIAL REPORTING

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 control over
financial  reporting  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.
While management  believes that these improvements were important to enhance the
Company's  ability  to  comply  with  its  disclosure  obligations,   management
concluded  that the Company's  system of disclosure  controls and procedures was
effective at the reasonable assurance level both prior to and after the changes.
The Company is not aware of any significant  deficiencies or material weaknesses
in its  internal  control  during  2004.  The Company did not make any  material
changes in its  internal  control  over  financial  reporting  during the fourth
quarter of 2004.

<PAGE>

DUE TO INHERENT LIMITATIONS,  OUR SYSTEM OF DISCLOSURE AND INTERNAL CONTROLS AND
PROCEDURES MAY NOT BE SUCCESSFUL IN PREVENTING ALL ERRORS OR FRAUD, OR IN MAKING
ALL MATERIAL INFORMATION KNOWN IN A TIMELY MANNER TO THE APPROPRIATE MANAGEMENT.

Though we have concluded with reasonable  assurance that our books,  records and
accounts  are kept in  reasonable  detail,  accurately  and fairly  reflect  the
transactions and dispositions of assets,  transactions are recorded as necessary
to permit  preparation  of financial  statements  in accordance  with  generally
accepted accounting  principles,  receipts and expenditures and access to assets
is permitted in accordance  with  authorizations  of management and directors of
the  Company,  we do not have  internal  auditors and we depend on a small staff
with which it is sometimes  difficult to segregate certain duties or to document
our practices in policies and procedures. Further,  notwithstanding management's
conclusions,  the  effectiveness of a system of disclosure and internal controls
and procedures is subject to certain  inherent  limitations,  including cost and
staffing limitations,  judgments used in decision making,  assumptions regarding
the likelihood of future events,  soundness of internal  controls and fraud. Due
to such inherent  limitations,  the  Company's  system of disclosure or internal
controls and procedures may not be successful in preventing all errors or fraud,
or  in  making  all  material  information  known  in a  timely  manner  to  the
appropriate  management.  In  addition,  we have not  completed  our  policy and
procedure documentation and testing of internal control over financial reporting
as required under Section 404 of the  Sarbanes-Oxley  Act. If we fail to achieve
and  maintain  the  adequacy of our internal  controls,  as such  standards  are
modified,  supplemented  or  amended  from  time to time,  we may not be able to
ensure that we can conclude on an ongoing basis that we have effective  internal
controls  over  financial  reporting in accordance  with Section 404.  Moreover,
effective  internal controls are necessary for us to produce reliable  financial
reports and are  important  to helping  prevent  financial  fraud.  If we cannot
provide reliable  financial reports or prevent fraud, our business and operating
results  could be  harmed,  investors  could  lose  confidence  in our  reported
financial   information,   and  the  trading  price  of  our  stock  could  drop
significantly.

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