SecProbe.io

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June 22, 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.
	Pre-effective Amendment 4 to Registration Statement on Form
SB-2
	Filed May 26, 2005
	File No. 333-121455
	Annual Report on Form 10-KSB for the fiscal year ended
December
31, 2004 and
	Quarterly Report on Form 10-QSB for the quarter ended March
31,
2005
	Filed March 31, 2005 and May 11, 2005
	File No. 333-47924

Dear Mr. Gordon:

	We reviewed the filings and have the comments below.

SB-2/A4

1. If applicable, comments on the SB-2 are comments on the 10-KSB
and
subsequent Exchange Act reports and vice versa.

2. We note the response to prior comment 3.  Revise the disclosure
on
page II-4 and also on page 25 in the 10-KSB to state that you
issued
to Andrew Garrett, Inc., the placement agent, a warrant to
purchase
4,970 shares and not 4,870 shares.

Company History, page 6

3. Your response to prior comments 6-10 helps to clarify the
company`s history.  However, the background and relationships
among
the companies discussed is still somewhat unclear.  For example,
the
first time that you mention BlastGard, Inc. you should explain
that
it was a separate company formed in 2000 and managed by Messrs.
Gordon, Waddell, and Gordon who later formed the company`s
subsidiary, BlastGard Technologies, Inc.

4. We note your revisions in response to prior comments 6 and 18.
Disclosure in the second full paragraph on page 7 indicates that
neither BTI nor BTI`s founders ever acquired any assets from
BlastGard, Inc.  Disclosure in the fourth paragraph on page 7
indicates that Opus acquired the "BlastGard" name from BlastGard,
Inc. at the direction of Opus`s new management team after Opus`s
reorganization with BTI.  These statements appear inconsistent
since
BTI controlled Opus and BTI`s founders were the same as Opus`
management when Opus acquired the "BlastGard" name.  Please revise
to
clarify.

5. Refer to prior comment 6.  Clarify in the last paragraph on
page 6
that The Verde Partners Limited Partnership or Verde was an
affiliated third party of BlastGard, Inc.  We note the disclosure
in
the second full paragraph on page 7 that BlastGard, Inc. was
formed
by Verde, C&L Trust, and James F. Gordon in 2000.

6. Disclose the names of the principals of Verde and C&L Trust.

7. Disclosure in the fourth full paragraph on page 7 states that
Opus
loaned $245,000 in July 2003, and by February 2004 BlastGard, Inc.
had no resources to repay the $250,000 loan.  Clarify whether the
amount of the loan was $250,000 or $245,000.

Additional Information Regarding Outstanding Convertible Notes
Payable, page 27

8. We read in your response to prior comment 2 that you were in
default on your $1.4 million convertible debt beginning on March
20,
2005.  Revise your discussion of the convertible debt here and in
note 4 of your March 31, 2005 financial statements to disclose the
default, the circumstances that led to the default, and the
potential
consequences of the default.  Disclose also, if true, that you now
are accruing the default interest rate plus penalties related to
this
debt, and disclose that interest rate.  Alternatively, you should
explain why you are not accruing the default interest rate plus
penalties.  Disclose also whether the interest rate on this debt
will
revert to 8% once the registration statement becomes effective or
if
it will remain at 15%.

Note 4.  Notes Payable, page F-10

9. You state in your response to prior comment 21 that neither the
convertible promissory notes nor the warrants contained conversion
features that were in-the-money at the commitment date.  It
appears
from your disclosure in note 4 that the convertible promissory
notes
were convertible at $1.50 per share on the date of issuance.  We
note
that due to the presence of the detachable warrants, the effective
conversion price of the convertible promissory notes appears to be
$1.15 per share.  We also note that your stock price on the date
of
issuance was $1.90 per share.  It appears to us that the
convertible
promissory notes include a beneficial conversion feature based on
the
provisions of EITF 98-5 and EITF 00-27.  Please clarify or revise.
Also, if applicable, revise the effective interest rate related to
the notes to reflect the beneficial conversion feature.

Note 5.  Options Granted to Employees, Accounted for under the
Intrinsic Value Method, page F-14

10. We note your response to prior comment 24 and the table that
you
added on page F-15.  It appears that the pro forma compensation
expense that you are disclosing only recognizes compensation
expense
for options that had vested before year end.  If this is true, it
is
unclear to us how you determined that this methodology meets the
requirement of paragraph 30 of SFAS 123 to recognize compensation
expense over the period(s) in which the related employee services
are
rendered.  Please clarify or revise.

Financial Statements of OPUS Resource Group, Inc. for the Year
Ended
December 31, 2003

11. Please conform these financial statements to those filed in
amendment 1 to the annual report on Form 10-KSB for the fiscal
year
ended December 31, 2003 on March 16, 2005.

Recent Sales of Unregistered Securities, page II-1

12. Refer to prior comment 25.  We note that you deleted the
exemption under the Securities Act that BlastGard relied upon.
Please revise.

Exhibit 10.17

13. Absent an order granting confidential treatment, Item
601(b)(10)
of Regulation S-K requires the filing of material contracts,
including attachments, in their entirety.  Attachments include,
for
example, appendices, exhibits, and schedules.  Refile the exhibit
in
its entirety to include exhibits A and B.

10-KSB

Debt issue costs, page F-12

14. Refer to prior comment 3. The disclosure on the number of
class A
and class B warrants issued to the placement agent is inconsistent
with the disclosure on page II-4 in the SB-2/A4.  Please revise.

Executive Compensation, page 30

15. Refer to prior comment 15.  Disclosure on page 36 that Mr.
Kevin
J. Sharpe was granted 500,000 options is inconsistent with
disclosure
on page 31 in the SB-2/A4 that Mr. Kevin J. Sharpe was granted
525,000 options.  Please revise.

Employment Contracts and Termination of Employment and Change-in-
Control Arrangements, page 32

16. Refer to prior comment 16.  Disclosure on page 32 that the
agreement with Mr. Kevin J. Sharpe provides an annual salary of
$100,000 per year is inconsistent with disclosure on page 33 in
the
SB-2/A4 that the agreement with Mr. Kevin J. Sharpe provides an
annual salary of $125,000 per year.  Please revise.

Closing

	File amendments to the SB-2 and the 10-KSB in response to the
comments.  To expedite our review, you may wish to provide us
three
marked courtesy copies of the amendments.  Include with the filing
any supplemental information requested and a cover letter tagged
as
correspondence that keys the responses to the comments.  If you
think
that compliance with any of the comments is inappropriate, provide
the basis in the letter.  We may have additional comments after
review of the amendments, the responses to the comments, and any
supplemental information.

	We urge all persons responsible for the accuracy and adequacy
of
the disclosure in the registration statement reviewed by us to
ensure
that they have provided all information investors require for an
informed decision.  Since BlastGard and its management are in
possession of all facts relating to the disclosure in the
registration statement, they are responsible for the adequacy and
accuracy of the disclosures that they have made.

      If BlastGard requests acceleration of the registration
statement`s effectiveness, BlastGard should furnish a letter at
the
time of the request, acknowledging that:

* Should the Commission or the staff acting by delegated authority
declare the registration statement effective, it does not
foreclose
the Commission from taking any action on the filing.

* The action of the Commission or the staff acting by delegated
authority in declaring the registration statement effective does
not
relieve BlastGard from its full responsibility for the adequacy
and
accuracy of the registration statement`s disclosures.

* BlastGard may not assert our comments or the declaration of the
registration statement`s effectiveness as a defense in any
proceedings initiated by the Commission or any person under the
United States` federal securities laws.

	The Commission`s Division of Enforcement has access to all
information that you provide us in our review of the registration
statement or in response to our comments on the registration
statement.

	We will consider a written request for acceleration of the
registration statement`s effectiveness under Rule 461 of
Regulation C
under the Securities Act as confirmation that those requesting
acceleration are aware of their responsibilities under the
Securities
Act and the Exchange Act as they relate to the proposed public
offering of the securities specified in the registration
statement.
We will act on the request and by delegated authority grant
acceleration of the registration statement`s effectiveness.

	You may direct questions on accounting comments to Jennifer
K.
Thompson, Staff Accountant, at (202) 824-5259 or Anne M.
McConnell,
Senior Staff Accountant, at (202) 942-1795.  You may direct
questions
on other comments and disclosure issues to Edward M. Kelly, Senior
Counsel, at (202) 942-1978 or me at (202) 942-1950.

Very truly yours,

Pamela A. Long

Assistant Director

cc:	Troy A. Young, Esq.
	Futro & Associates, P.C.
	Alamo Plaza
	1401 17th  Street, Suite 1150
	Denver, CO 80202

Mr. Michael J. Gordon
June 22, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE

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