PACIFICHEALTH LABORATORIES, INC.


May 2, 2006



Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, NE
Washington, D.C.   20549

Re:   Pacifichealth Laboratories, Inc.
      Form SB-2/A
      Amendment to Registration Statement on Form SB-2
      File No. 333-109197
      ------------------------------------------------



Ladies and Gentlemen:

Pursuant to Rule 477 under the Securities Act of 1933, as amended, Pacifichealth
Laboratories, Inc. (the "Company") requests the withdrawal of the Amendment to
Registration Statement on Form SB-2 (File No. 333-109197) that was filed with
the Securities and Exchange Commission on April 26, 2006. This Amendment was
intended to be filed as a post-effective amendment to the Registration
Statement, but was inadvertently labeled as Form SB-2/A when submitted via
EDGAR. The Company is re-filing this Amendment as a Post-Effective Amendment to
Registration Statement (File No. 333-109197) on or about the time of the filing
of this letter.

If you have any questions regarding this request for withdrawal, please do not
hesitate to contact Gary A. Miller of Eckert Seamans Cherin & Mellott, our
outside counsel, at 215-851-8472.


Sincerely,

PACIFICHEALTH LABORATORIES, INC.


By: Stephen P. Kuchen
    --------------------------------
    Stephen P. Kuchen
    Chief Financial Officer
    Pacifichealth Laboratories, Inc.