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ADVANSTAR, INC.
545 Boylston Street
Boston, Massachusetts 02116
Telephone: (617) 267-6500
Fax: (617) 267-6900
May 25, 2000
Via Edgar and Overnight Delivery
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Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, N.W.
Washington, DC 20549
Re: Advanstar, Inc.
Request to Withdraw Registration Statement on Form S-1, as amended
(Registration No. 333-74683)
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Securities and Exchange Commission:
Pursuant to Rule 477 of Regulation C of the Securities Act of 1933, as
amended (the "Act"), Advanstar, Inc. (the "Registrant") hereby respectfully
applies to the Securities and Exchange Commission (the "Commission") for consent
to the withdrawal of the above-referenced registration statement on Form S-1, as
amended (the "Registration Statement"), with such application to be approved
effective as of the date hereof or at the earliest practical date thereafter, on
grounds that withdrawal of the registration statement is consistent with the
public interest and the protection of investors, as contemplated by paragraph
(a) of Rule 477. The Registration Statement was initially filed through the
Commission's Electronic Data Gathering, Analysis and Retrieval system ("EDGAR")
on March 19, 1999 and amended on April 22, 1999 via EDGAR.
The Registration Statement was filed in connection with a proposed initial
public offering of the Registrant's common stock, par value $.01 per share
("Common Stock"). The Registrant has determined that it will not proceed with
the registration and sale of Common Stock as contemplated in the Registration
Statement. Because the Registrant will not proceed with the proposed offering,
the Registrant's management believes that withdrawal of the Registration
Statement is appropriate.
The Registrant confirms that no securities have been issued or sold
pursuant to the Registration Statement. The filing fee for the Registration
Statement was paid by electronic wire transfer to the Commission at the time of
the initial filing and the Registrant understands that such fees will not be
returned to it.
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Securities and Exchange Commission
May 25, 2000
Please provide the Registrant with a facsimile copy of the order consenting
to the withdrawal of the Registration Statement as soon as it is available. The
facsimile number of the Registrant is (617) 267-6900.
Sincerely,
ADVANSTAR, INC.
By:/s/ Robert L. Krakoff
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Robert L. Krakoff
Chairman of the Board and Chief Executive
Officer
cc: Robert L. Plesnarski, Mail Stop 4-9 (Securities and Exchange Commission)
Eric I. Lisman (Advanstar, Inc.)
David W. Montgomery (Advanstar, Inc.)
Ralph Hamann (Advanstar, Inc.)
F. George Davitt (Testa, Hurwitz & Thibeault, LLP)
Mark T. Bettencourt (Testa, Hurwitz & Thibeault, LLP)
Victor I. Chang (Testa, Hurwitz & Thibeault, LLP)