CIRO INTERNATIONAL, INC.
445 Fifth Avenue, Suite 11A
New York, NY 10016
(212) 481-1322
February 2, 2000
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549
Attn: Kenneth Lench
Re: Ciro International, Inc.
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Registration Statement on Form 10-SB
File No. 000-28699
Dear Mr. Lench:
In accordance with regulation 230.477(c) of the Securities Act of 1933, as
amended, please consider this letter as an application for the withdrawal of the
captioned registration statement on Form 10-SB (the "Registration Statement")
filed on behalf of Ciro International, Inc. (the "Company").
Such withdrawal will allow the Company to fully and accurately respond to the
Commission's preliminary comments to the Registration Statement. The Board of
Directors of the Company believes that the withdrawal of the Registration
Statement and filing of a new registration statement that is responsive to the
Commission's comments is consistent with the public interest and protection of
investors.
We seek that the Commission consent to such withdrawal and issue the appropriate
order.
Sincerely,
CIRO INTERNATIONAL, INC.
By: /s/ Murray A. Wilson
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Murray A. Wilson,
President
