Cindy Shy, P.C.
A professional law corporation
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525 South 300 East * Salt Lake City, Utah 84111 * Telephone (801) 323-2392
February 18, 2000
James M. Daly
Assistant Director
United States Securities and Exchange Commission
Washington, D.C. 20549
RE: Winners Internet Network, Inc.
Form 10-SB filed December 23, 1999
File No. 0-28641
Dear Mr. Daly,
Winners Internet received its first comment letter from your office
regarding the above identified registration statement on February 17, 2000.
Winners Internet acknowledges that the 60 day comment period will pass before
it will be able to address such comments. Accordingly, Winners Internet
withdraws the registration statement pending resolution of the pending
comments and requests your prompt consent to such withdrawal prior to the
effective date of February 22, 2000.
It is the intention of Winners Internet to refile the registration
statement addressing the pending comments and recent changes in the direction
of Winners Internet.
This letter is countersigned by David Skinner, Jr., President of Winners
Internet who is authorized to take this action.
Thank you for your cooperation in this matter.
Sincerely,
/s/ Cindy Shy
Cindy Shy
Attorney
WINNERS INTERNET NETWORKS, INC.
/s/ David Skinner, Jr.
By: ________________________________
David Skinner, Jr.
President
