SecProbe.io

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January 19, 2005

By facsimile to (303) 295-1563 and U.S. Mail

Mr. Michael J. Gordon
Chief Financial Officer and Vice President, Corporate
Administration
BlastGard International, Inc.
12900 Automobile Boulevard, Suite D
Clearwater, FL 33762

RE:	BlastGard International, Inc., formerly OPUS Resource Group,
Inc.
	Registration Statement on Form SB-2 and Pre-effective
Amendments
1 and 2
	Filed December 20, 2004 and January 7 and 11, 2005
	File No. 333-121455
	Annual Report on Form 10-KSB and Subsequent Exchange Act
Reports
	File No. 333-47924

Dear Mr. Gordon:

	We reviewed the filings and have the comments below.

	Where indicated, we think that you should revise the
documents
in response to the comments.  If you disagree, we will consider
your
explanation why a comment is inapplicable or a revision is
unnecessary.  Be as detailed as necessary in your explanation.  To
understand better your disclosure, we may ask you in some comments
to
provide us supplemental information.  We may raise additional
comments after reviewing this information.

	Our review`s purpose is to assist you in your compliance with
applicable disclosure requirements and to enhance the overall
disclosure in your documents.  We look forward to working with you
to
achieve these objectives.  We welcome any questions that you may
have
about comments or any other aspect of our review.  You may call us
at
the telephone numbers listed at the end of this letter.

SB-2

1. If applicable, comments on the SB-2 are comments on the 10-KSB
and
subsequent Exchange Act reports and vice versa.  Comply with the
comments in the SB-2 and, if applicable, in future Exchange Act
filings.

2. Provide an updated consent from the independent accountant in
each
amendment to the SB-2.

3. Provide updated financial statements and related disclosures,
as
necessary, to comply with Item 310(g) of Regulation S-B.

4. Since BlastGard International, Inc. or BlastGard is a penny
stock
issuer, the Private Securities Litigation Reform Act of 1995`s
safe
harbor for forward looking statements is inapplicable.  See
section
27A(b)(1)C) of the Securities Act, and revise the first paragraph
on
page 22 and elsewhere.

Calculation of Registration Fee Table

5. We note that BlastGard is registering 150% of the amount of
shares
that would be issuable currently upon the notes` conversion under
an
agreement with the noteholders.  We believe that it is appropriate
to
register for resale only that number of shares that BlastGard in
good
faith estimates that it will actually issue upon conversion.  If
the
notes actually convert into a greater number of shares, BlastGard
may
file a resale registration statement for the excess shares at that
time.  Tell us the basis for BlastGard`s estimate that it will
issue
150% of the amount into which the notes would convert currently.

6. Disclosure that BlastGard is registering 146,969 shares of
common
stock that represent shares issuable upon exercise of common stock
purchase warrants at an exercise price of $3.00 per share is
inconsistent with disclosures on pages 33-34 that BlastGard issued
class B common stock purchase warrants to acquire 141,999 shares
and
a warrant to purchase 4,870 shares at an exercise price of $3.00
per
share which total 146,869 shares.  Revise or advise.

7. The total number of shares shown as being registered,
4,011,340,
is inconsistent with the maximum number of shares being offered as
shown in the table on pages 31-32, 3,712,340.  Revise or advise.

Prospectus` Outside Front Cover Page

8. If the prospectus will be used before the registration
statement`s
effectiveness, include a prominent statement that the prospectus
is
not complete and registration is not effective.  See Item
501(a)(10)
of Regulation S-B.

9. It appears that BlastGard`s common stock is quoted on the Over
the
Counter Bulletin Board under the symbol BLGA.OT, not BLGA.  Revise
here and elsewhere in the registration statement.

Cautionary Statements Concerning Forward-Looking Statements, page
2

10. Remove the reference to documents incorporated by reference
from
the penultimate paragraph because this prospectus does not
incorporate by reference.

Risk Factors, page 3

11. Some risk factors` captions or headings state merely a fact or
describe an event that may occur in the future or are too vague to
describe adequately the risk that follows.  For example, refer to
the
first, second, fourth, sixth, seventh, eighth, ninth, tenth,
eleventh, twelfth, thirteenth, fourteenth, fifteenth, seventeenth,
and eighteenth risk factors.  State succinctly the risk that flows
from the fact or uncertainty.

12. Include in each risk factor`s discussion information necessary
to
assess the risk, including its magnitude.  For example:

* The fourth risk factor states that BlastGard will likely require
additional financing to carry out its business plans over the next
12
months.  Quantify the known or estimated amount of capital that
BlastGard will require to carry out its business plans over the
next
12 months.

* The sixth risk factor states that BlastGard`s primary sales
focus
is to distribute its products through strategic partners, direct
sales, information, and education.  Expand the risk factor
disclosure
to indicate whether BlastGard has entered into an agreement with
any
strategic partners and to specify BlastGard`s schedule for
organizing
its sales and marketing department.

* The eighth risk factor states that BlastGard`s future is
dependent
upon the success of the current and future generations of one or
more
of the products that BlastGard proposes to sell.  Expand the risk
factor disclosure to clarify whether BlastGard has any products
available for sale, and, if so, whether BlastGard has completed
any
sales of the products as of the most recent date of the
prospectus.

* The ninth risk factor states that BlastGard intends to rely on
outside suppliers for its products.  Expand the risk factor
disclosure to clarify whether BlastGard has identified any outside
suppliers and whether BlastGard has entered into any agreements
with
outside suppliers for its products.

* The sixteenth risk factor states that the market price of
BlastGard`s common stock is highly volatile.  Quantify the high
and
low bid prices of BlastGard`s common stock during the past 52 week
period.  Further, clarify that the quotations reflect interdealer
prices without retail markup, markdown, or commission and may not
represent actual transactions.

* The seventeenth risk factor states that future sales of common
stock by BlastGard`s management and others may affect adversely
the
current market price of BlastGard`s common stock, may affect
adversely BlastGard`s ability to obtain future funding, and create
a
potential market overhang.  Quantify the number of shares of
BlastGard`s common stock that may be subject to future sales by
its
management and others.

13. The second risk factor states that BlastGard`s independent
public
accountants have included a going concern qualification in their
opinion.  Expand the risk factor disclosure to include the risk of
using BlastGard`s financial statements because they do not include
any adjustments to asset carrying values or the classification of
liabilities that might result should BlastGard be unable to
continue
as a going concern.  Further, include a discussion of:

* The rate at which BlastGard burned cash in the interim periods
since December 31, 2003.

* The costs of any planned research and development activities for
developing new product lines and for maintaining, improving, or
enhancing existing product lines.

* Any significant changes in the number of employees.

* Other known or estimated material operational costs.

14. The twelfth risk factor states that BlastGard relies on a
combination of patent applications, trademarks, copyright and
trade
secret laws, and confidentiality procedures to protect its
intellectual property rights.  Expand the risk factor disclosure
to
state clearly that BlastGard has no patents and to address these
and
other material risks relating to each of BlastGard`s patent
applications:

* A patent may never be issued on any of BlastGard`s applications.

* Even if a patent is issued, BlastGard`s use of the patented
technology may infringe upon patents issued to third parties,
subjecting BlastGard to the cost of defending the patent and
possibly
requiring BlastGard to stop using the technology or to license it
from another party.

* Third parties may infringe on a patent issued to BlastGard.  If
so,
BlastGard will bear the cost of enforcing the patent.

15. If the party with whom BlastGard entered into the failed 2003
distribution agreement, BlastGard, Inc., and BlastGard
Technologies,
Inc. are not the same company as suggested in the 2003 10-KSB,
discuss supplementally with a view toward including appropriate
risk
factor disclosure the risk of claims by BlastGard, Inc. of
violation
of its patents, trademarks, tradenames, etc. by BlastGard
Technologies, Inc. or BlastGard International, Inc.  Consider any
other risks that could stem from confusion about participation in
the
same market by two participants with similar names and disclose
them
as appropriate.

16. It appears that trading in BlastGard`s common stock is subject
to
the penny stock rules under the Exchange Act and that the shares
to
be sold in this offering will be penny stocks.  Revise the
eighteenth
risk factor to state clearly that BlastGard`s common stock is
subject
to the penny stock rules and to describe concisely but
comprehensively the compliance actions required under Rules 15g-2
through 15g-9 under the Exchange Act.  Then explain the risks to
investors resulting from required compliance with these
regulations
such as price fluctuations and the lack of a liquid market.

17. Avoid generic conclusions in the risk factors` captions or
headings and in the risk factors` discussions such as BlastGard`s
result of operations, business, and financial condition would or
could be materially and adversely affected or would or could be
harmed.  For example, refer to the seventh risk factor.  Rather,
explain specifically what the risk`s consequences or effects are
for
BlastGard and its securityholders.

18. Eliminate generic or vague bullet points in the risk factors`
discussions.  For example, refer the last bullet point in the
sixteenth risk factor.

19. The actual risk that you are trying to convey does not stand
out
from the extensive detail that you provide in the fourteenth risk
factor.  Revise so that you are stating the risk in at least the
second or third sentence.  Provide just enough detail to place the
risk in context.

20. Some risk factors include language like "There is no
assurance,"
"No assurances can be given," "We can provide no assurances," and
"There can be no assurance."  For example, refer to the first,
second, third, fourth, fifth, seventh, eighth, ninth, twelfth,
fourteenth, and fifteenth risk factors.  Since the risk is the
situation described and not BlastGard`s inability to assure,
revise.

21. Disclosure on page 7 states that BlastWrap must be replaced
after
a single intense detonation.  Address in a discrete risk factor
any
material risks to BlastGard and BlastGard`s customers and
investors
resulting from the requirement of replacing BlastWrap after a
single
intense detonation.

Description of Business, page 6

22. Include a prominent statement here and in the prospectus
summary
that BlastGard is a development stage company and its planned
principal operations have not begun or have not produced yet
significant revenues.  Also revise the first sentence of this
section`s second paragraph that suggests that BlastGard is
actively
engaged in the manufacture and marketing of blast mitigation
materials at this time.

23. Ensure that BlastGard describes the development of its
business
over the past three years as required by Item 101 of Regulation S-
B.
We note that the 2003 10-KSB contains disclosure of developments
that
have taken place within the past three years, back to and
including
2002, that is not included in the description of business section
in
the prospectus.

24. Where information about BlastGard, BlastGard`s business, or
the
industries in which BlastGard operates or may operate is
presented,
disclose the factual basis of the information.  If the information
is
not factually supportable, state that the information is
BlastGard`s
belief or remove the statement.  Examples of these statements
include
but are not limited to those such as:

* BlastGard`s BlastWrap products offer a revolutionary blast
protection system against all blast and fire/burn threats.

* BlastWrap constitutes a dramatic innovation in safety.

* Strong mitigation of impulse provided by BlastWrap is virtually
impossible to reproduce through any other low-weight approach.

* BlastGard`s technology is the only blast and fire suppression
means
available for most applications.

* BlastWrap can be easily updated and deployed to address the
problems involving explosive materials specific to the oil and gas
industry.

* BlastGard`s technology will add value to almost all
manufacturing
facilities of explosives, propellants, munitions, and
pyrotechnics.

* BlastGard offers the unique ability to convert standardized
chipping containers into explosive storage units that comply with
the
technical requirements of the United States Bureau of Alcohol,
Tobacco, and Firearms type 2 magazines.

* BlastWrap technology is unique in quenching blast areas.

* BlastGard has an unrivaled understanding of the mechanics of
explosions.

* BlastGard`s products would dramatically mitigate or suppress
fireballs and explosions produced by all of the fuels now being
used
or considered for commercial introduction, for at least the next
two
decades.

* BlastGard`s engineers and design personnel are some of the
premier
experts in the field of blast effect mitigation.

* BlastWrap protection of military aircraft should be top priority
for the United States Department of Defense.

25. Disclosures on page 2 in the 10-KSB and on page 22 in the SB-2
and elsewhere state that:

* BlastGard acquired 100% of the issued and outstanding common
stock
of BlastGard Technologies, Inc. or BTI from BTI`s shareholders in
exchange for 91 million shares of BlastGard`s common stock on
January
31, 2004.

* BTI is not the same entity as BlastGard, Inc., and BTI`s
technology
is not the same as BlastGard, Inc.`s technology.

* BTI acquired its only significant asset, a patent application
for
BlastWrap, in January 2004.

Clarify here that although BTI was an affiliate of BlastGard, Inc.
before the exchange, BTI`s technology is not the same as
BlastGard,
Inc.`s technology.  Also clarify here from whom BTI acquired the
patent application for BlastWrap, and state what consideration BTI
paid for the application.

26. Disclosure on page 8 and elsewhere states that BlastWrap
prototypes have been evaluated in different test series.  For each
of
BlastGard`s products such as those listed in items 1-10 on page
10,
clarify whether a prototype exists, the degree to which product
design has progressed, and whether further engineering is
necessary.
Further, clarify which BlastWrap products are actually being
manufactured and marketed as of the most recent date practicable.
See Item 101(b)(1) of Regulation S-B.

27. We note that the paragraphs entitled "3.  Explosive Storage
Units
- ESU" and "4.  BlastMag-2" suggest that BlastGard has contracts
with
or orders from Lockheed Martin Missiles and Space Company and
Autoliv, Inc.  Describe BlastGard`s arrangements with these
companies
in more detail, and file copies of these agreements as exhibits to
the registration statement.

28. Disclosures on pages 10, 11, and 14 state that:

* The Department of Defense approved the explosive storage units
designed for Lockheed Martin Missiles and Space Company.

* BlastGard`s weap