<PAGE>
(CORNERSTONE BRANDS, INC. LETTERHEAD)
July 8, 1999
VIA EDGAR
- - ---------
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: Cornerstone Brands, Inc.
Registration Statement on Form 8-A (File No. 001-14511)
-------------------------------------------------------
Ladies and Gentlemen:
Cornerstone Brands, Inc. (the "Company") filed with the Securities and Exchange
Commission a registration statement on Form 8-A on September 23, 1998 (the "8-A
Registration Statement"). Concurrently with this letter, the Company is filing
a letter requesting that its related registration statement on Form S-1 (File
No. 333-62235) be withdrawn pursuant to Rule 477(a) under the Securities Act of
1933, as amended. Therefore, the Company hereby requests that the 8-A
Registration Statement also be withdrawn.
If you have any questions or comments or require further information or
documentation, please do not hesitate to call the undersigned at (207) 780-6585
or Patrick J. Rondeau, Esq. at (617) 526-6670.
Sincerely,
/s/ William T. End
William T. End
Chief Executive Officer