SecProbe.io

MAIL STOP 3561

March 18, 2008

By U.S. Mail and facsimile to (718) 768-4731

Mr. Andrew Gordon, President, CEO and CFO Coffee Holding Co., Inc. 4401 First Avenue Brooklyn, NY 11232-0005

Re: Coffee Holding Co., Inc.
Form 10-K for Fiscal Year Ended October 31, 2007 Filed February 1, 2008 File No. 001-32491

Dear Mr. Gordon:
  We have reviewed your filings and have the following comments.  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 information so we may better understand your disclosure.  After reviewing this information, we may 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 any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.     Management Discussion and Analysis of Fina ncial Condition and Results of Operations,
page 20

Andrew Gordon
Coffee Holding Co., Inc. March 18, 2008 Page 2

1. Tell us why you have not provided a tabular disclosure of contractual obligations
as required by Item 303 of Regulation S-K.

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 information.  Detailed cover letters greatly facilitate our review.  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 filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment 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
filing;
‚ staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; 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 Di vision of Corporation Finance in our review
of your filing or in response to our comments on your filing.

Andrew Gordon
Coffee Holding Co., Inc. March 18, 2008 Page 3
  You may contact Joshua Thomas, Sta ff Accountant, at (202) 551-3832 or Tia
Jenkins, Senior Assistant Chief Accountan t, at (202) 551-3871 if you have questions
regarding comments on the financial statements and related matters.  Please contact me with any other questions.

       S i n c e r e l y ,           T i a  J e n k i n s        Senior Assistant Chief Accountant
Office of Beverages, Apparel and  Health Care Services