GLOBAL CONCEPTS, LTD.
                            14 Garrison Inn Lane
                             Garrison, NY 10524
                                845-424-4100
 
February 1, 2005

Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549

   Re:  Global Concepts, Ltd. 
        Registration Statement on Form SB-2 (File No. 333-121043)
			
Ladies and Gentlemen:

Pursuant to Rule 477 under the Securities Act of 1933, as amended, Global 
Concepts, Ltd. hereby applies for withdrawal of the above-referenced
Registration Statement on Form SB-2, which was filed with the Securities
and Exchange Commission on December 7, 2004.

The Registration Statement was filed in contemplation of a public offering
by two selling shareholders.  Global Concepts is withdrawing the Registration
Statement at the request of the selling shareholders, as a result of a
substantial modification of the contractual relationship between Global
Concepts and the selling shareholders.  The Registration Statement has not
been declared effective, and none of the securities included in the
Registration Statement have been sold in connection with the offering.

Please provide, by facsimile, a copy of the order granting withdrawal of
the Registration Statement to our legal counsel, Robert Brantl
(facsimile: 718-965-4042).  If you have any questions with regard to
this application for withdrawal, please contact Mr. Brantl at 718-768-6045.  


                                        Global Concepts, Ltd.

                                        By: /s/ Michael Margolies
                                        ---------------------------
                                        Michael Margolies, Chairman