July 8, 1998
Securities and Exchange Commission
Filing Desk
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: NU SKIN ASIA PACIFIC, INC. (RENAMED NU SKIN ENTERPRISES, INC.)
Registration Statement on Form S-1
Commission File No. 333-28513
Dear Ms. Parratt and Mr. Link:
Pursuant to Rule 477 of the General Rules and Regulations promulgated
under the Securities Act of 1933, as amended, Nu Skin Asia Pacific, Inc.
(renamed Nu Skin Enterprises, Inc.) (the "Company") hereby applies for an order
granting the immediate withdrawal of its Registration Statement on Form S-1,
together with all exhibits, Commission File No. 333-28513 (the "Registration
Statement"). The Registration Statement was originally filed with the Securities
and Exchange Commission (the "Commission") on June 4, 1997.
Pursuant to the Registration Statement, the Company proposed to register
certain shares of its Class A Common Stock, $.001 par value per share for
issuance to the public (the "Offering"). The Company, upon consultation with the
underwriters, has decided not to proceed with the Offering at this time. No
securities have been sold under the Registration Statement and all activity in
pursuit of the Offering has been discontinued.
The Company hereby requests that the Commission issue an order granting
the aforementioned withdrawal of the Registration Statement effective as soon as
possible.
Sincerely,
NU SKIN ENTERPRISES, INC.
By: /s/ Steven J. Lund
Steven J. Lund
Its: President and Chief Executive Officer
