SecProbe.io

October 28, 2010
 Biolargo, Inc. Charles K. Dargan II, Chief Financial Officer 16333 Phoebe Ave. La Mirada, CA  90638

Re: Biolargo, Inc.
 Form 10-K for the fiscal year ended December 31, 2009
  Form 10-Q for the quarter ended March 31, 2010
Form 10-Q for the quarter ended June 30, 2010 File No. 0-19709

Dear Mr. Dargan:
 We have reviewed your response to our comm ent letter dated October 5, 2010 and have
the following comments.  In some of our co mments, we may ask you to provide us with
information so we may better understand your disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Form 10-K for the year ended December 31, 2009

Item 9A. Controls and Procedures, page 37
 Management’s Report on Internal Cont rol over Financial Reporting, page 37

1. We note your response to prior comment tw o in our letter dated October 5, 2010 and
appreciate the additional information.  We not e that you are not planning to amend your
Form 10-K for the year ended December 31, 2009 to include management’s report on
internal control over financial reporting.  Please be advised, as  discussed in Compliance
and Disclosure Interpretation 115.02, which you can find at
http://www.sec.gov/divisions/corpfin/guidance/regs-kinterp.htm , failure to file management's
report on Internal Control over Financial Reporting rendered your annual report materially
deficient and the company would be considered not timely or current in its Exchange Act reporting.

Charles K. Dargan II  Biolargo, Inc. October 28, 2010 Page 2

Form 10-Q for the quarter ended March 31, 2010

Form 10-Q for the quarter ended June 30, 2010
 Exhibits 31.1 and 31.2

2. We note your response to prior comment th ree in our letter dated October 5, 2010;
however, your certifications included in your  Form 10-Q filings for the periods ended
March 31, 2010 and June 30, 2010 do not materia lly comply with the requirements of
Item 601(b)(31) of Regulation S-K as they omit the introductory language in paragraph 4
and required language in paragr aph 4(b) referring to intern al control over financial
reporting as required by Item 601( b)(31) of Regulation S-K.  Therefore, we continue to
believe that you should amend your above men tioned Form 10-Q filings to include the
aforementioned language in your certifications .  Each of your amendments may consist
of a cover page, explanatory note, signature  page and paragraphs 1, 2, 4, and 5 of the
certifications.

You may contact Mindy Hooker at (202) 551-3732 or me at (202) 551-3768 with any
questions.
Sincerely,
       John Cash
Branch Chief