LETTER 1 filename1.txt January 4, 2006 Mr. Fred W. Rickert Chief Financial Officer Maui Land & Pineapple Company, Inc. 120 Kane Street, P.O. Box 187 Kahului, Maui, Hawaii 96733 Re: Maui Land & Pineapple Company, Inc. Form 10-K for Fiscal Year Ended December 31, 2004 Filed March 29, 2005 File No. 001-06510 Dear Mr. Rickert: We have completed our review of your Form 10-K and related filings and do not, at this time, have any further comments. Sincerely, Jill S. Davis Branch Chief ?? ?? ?? ?? Mr./Ms. Company Name Date, 2005 page 1 UNITED STATES SECURITIES AND EXCHANGE COMMISSION 100 F Street, NE WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE MAIL STOP 7010