<PAGE>
[ADVANCED NUTRACEUTICALS, INC. LOGO APPEARS HERE]
2715 Bissonnet Suite 305
Houston, TX 77005
October 27, 1998
Securities and Exchange Commission
Division of Corporate Finance
Mail Stop 3-9
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: John L. Krug, Esq.
Ladies and Gentlemen:
In accordance with Rule 477 promulgated under the Securities Act of
1933, as amended, we hereby request withdrawal of the Registration Statement on
Form S-1 (File No. 333-63473) (the "Registration Statement") for Advanced
Nutraceuticals, Inc. (the "Registrant").
The Registrant is requesting withdrawal of the Registration Statement
because the Registrant's underwriter has informed it that the Registrant's
initial public offering is impracticable in today's market environment on
acceptable terms.
If you have any questions regarding this request for withdrawal of the
Registration Statement, please feel free to contact the undersigned at
(713)874-1440, or David L. Gersh, Esq. at Paul, Hastings, Janofsky & Walker LLP,
counsel to the Registrant, at (213)683-6240.
Very truly yours,
/s/ Barry C. Loder
Barry C. Loder
President (Principal Executive,
Accounting and Financial Officer)
