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Timberland Growth Corporation
2000 West Park Drive
Suite 125
Westborough, MA 01581
Fax: (508) 616-0003
April 5, 1999
VIA EDGAR
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Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549
Re: Withdrawal of Registration Statement on Form S-11
(File No. 333-48041) of Timberland Growth Corporation
Ladies and Gentlemen:
Pursuant to Rule 477 under the Securities Act of 1933, as
amended (the "Act"), Timberland Growth Corporation hereby
requests that its Registration Statement on Form S-11 (File No.
333-48041), as amended, be withdrawn from registration under the
Act.
If you have any questions about this request for
withdrawal, please contact David Lamarre of Pillsbury Madison &
Sutro LLP at (415) 983-6470.
Very truly yours,
/s/ Allan F. Trinkwald
Allan F. Trinkwald
Vice President, Chief Financial
Officer and Treasurer