ORBITEX GROUP OF FUNDS
AW, 1999-10-06
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                             REQUEST FOR WITHDRAWAL


         The undersigned Registrant respectively requests,  pursuant to Rule 477
under the Securities  Act of 1933,  that  Post-Effective  Amendment No. 7 to its
Registration  Statement  on Form N-1A (File No.  333-20635)  be  withdrawn.  The
Post-Effective  Amendment was filed  primarily for the purpose of permitting the
Registrant to offer shares in two new Funds.  The  Registrant  has now concluded
that it does not  desire to offer  shares  in those two new Funds at this  time,
and, therefore does not wish the  Post-Effective  Amendment to become effective.
Registrant will continue to offer shares of its existing Funds,  pursuant to its
existing Prospectus and Statement of Additional Information, both dated July 12,
1999. To permit the  Post-Effective  Amendment to become effective may result in
confusion among investors regarding the two new Funds which will not be offered.
Accordingly,  the  Registrant  believes that  withdrawal  of the  Post-Effective
Amendment  is  consistent  with  the  public  interest  and  the  protection  of
investors.

         Respectfully, submitted this 6th day of October, 1999.

                                                  ORBITEX GROUP OF FUNDS

                                                  By     /s/ M. Fyzul Khan
                                                    ----------------------------
                                                        M. Fyzul Khan, Secretary




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