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Chemical Logistics Corporation
808 Travis, Suite 1601
Houston, Texas 77002
March 9, 1999
Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549
Re: Chemical Logistics Corporation Form S-1 (File Number 333-59743)
Ladies and Gentlemen:
This application is made by Chemical Logistics Corporation ("CLC")
pursuant to Rule 477 under the Securities Act of 1933, as amended, for
permission to withdraw its registration statement (the "Registration
Statement") on Form S-1 (File Number 333-59743) that was originally filed with
the Securities and Exchange Commission (the "Commission") on July 24, 1998.
The withdrawal requested hereby is being sought for the following
reasons: (a) CLC has determined that it is not in its best interests to conduct
the offering of the Common Stock contemplated in the Registration Statement at
this time; (b) the Registration Statement has not been declared effective by
the Commission; and (c) market conditions are currently unfavorable. No Common
Stock has been offered, issued or sold under the Registration Statement.
On the basis of the foregoing, CLC respectfully requests that the
Commission grant its application to withdraw the Registration Statement.
Should you have any questions or require anything further, please call
Francis S. Kalman at (713) 228-1555.
Very truly yours,
CHEMICAL LOGISTICS CORPORATION
By: /s/ FRANCIS S. KALMAN
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Francis S. Kalman
Chief Financial Officer
cc: Stephen D. Brown
New York Stock Exchange