KENNETH M. CHRISTISON
ATTORNEY AT LAW
51 PARTIDGE DRIVE
NOVATO, CA 94945
TELEPHONE: 415-898-6829
FACSIMILE: 415-898-7519
October 31, 1999
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: Topaz Group, Inc.: File No. 0-27415
Dear Madam or Sir:
On behalf of Topaz Group, Inc. (the "Company"), I hereby request withdrawal
of the Form 10 Registration Statement, File No. 0-27415, filed September
22, 1999. The Company intends to re-file its Form 10 at such time as
necessary changes have been made to assure the Company's financial
statements comply with the SEC Regulation S-X Rule 2-02.
Please call me at 415-898-6829 if there are any questions.
Very truly yours,
Kenneth M. Christison
Attorney for Topaz Group, Inc.
ccs: Topaz Group, Inc.
John Klopper, Esq. Div of Corp. Finance