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HEADHUNTER.NET
September 18, 1998
Via EDGAR and Facsimile
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: HeadHunter.NET, Inc.; Registration Statement on Form S-1
(Reg. No. 333-59389)
Ladies and Gentlemen:
Pursuant to Rule 477 under the Securities Act of 1933, as amended, the
undersigned registrant, HeadHunter.NET, Inc. (the "Company"), hereby requests
the Commission's consent to withdraw the above-referenced Registration
Statement.
This request is made because the Company believes that current market
conditions are not conducive to an initial public offering of common stock by
the Company and that market conditions in the Company's industry are unlikely
to improve until 1999. The Company believes that withdrawal of the
Registration Statement is consistent with the public interest and the
protection of investors, particularly because neither the Company nor its
underwriters circulated preliminary prospectuses in connection with the
proposed offering or otherwise engaged in active marketing of the
Company's common stock. Accordingly, the Company respectfully requests that
the Commission grant its request to withdraw the Registration Statement.
If you have questions or comments about the foregoing, please call the
undersigned at (770) 300-9272 or Joel J. Hughey or Adam V. Battani of Alston &
Bird LLP at (404) 881-7000.
Sincerely,
/s/ Warren L. Bare
Warren L. Bare
Chief Executive Officer
cc: Rebecca A. Bohland
Joel J. Hughey, Esq.
Adam V. Battani, Esq.
