May 31, 2000
VIA EDGAR
Securities and Exchange Commission
450 Fifth Street N.W.
Washington, D.C. 20549
Re: Ubarter.com Inc.
Registration Statement on Form SB-2 (File No. 333-71411)
Ladies and Gentlemen:
Pursuant to Rule 477 of the Securities Act of 1933, please accept this
letter as a request for the Commission's consent to the withdrawal of our
Registration Statement referenced above. This Registration Statement has been
terminated due to the proposed acquisition of Ubarter.com Inc. Under separate
cover, Ubarter.com Inc. will file a Form 15 Certification and Notice of
Termination of Registration under Section 12(g) of the Securities Exchange Act
of 1934.
Upon the grant of the Commission's consent hereto, please return a dated
copy of the order granting such withdrawal, which order shall state "Withdrawn
upon the request of the registrant, the Commission consenting thereto," and
which is to be included in the file for the Registration Statement.
Otherwise, please direct all inquiries to Robert Benson at (206) 239-1005.
Respectfully,
UBARTER.COM INC.
/s/ STEVEN WHITE
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Steven White
Chairman and Chief Executive Officer
