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[LETTERHEAD OF POWELL, GOLDSTEIN, FRAZER & MURPHY LLP APPEARS HERE]
Suzanne J. Roberts
Direct Dial: 404-572-6896
Email: [email protected]
December 2, 1999
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549
Re: Cybernet Internet Services International, Inc.
Registration Statement on Form S-1 (File No. 333-91595)
Ladies and Gentlemen:
We are counsel for Cybernet Internet Services International, Inc. (the
"Company") and are authorized to furnish this letter. The automatic delaying
amendment language was inadvertently omitted from the above referenced
registration statement. The Company wishes to have the effective date of that
registration statement delayed until the Company files a request for
acceleration of the effectiveness thereof. Therefore, please consider the
following language incorporated into the above registration statement, pursuant
to Rule 473 under the Securities Act of 1933, as amended:
"The registrant hereby amends this registration statement on such date
or dates as may be necessary to delay its effective date until the
registrant shall file a further amendment which specifically states that
this registration statement shall thereafter become effective in accordance
with Section 8(a) of the Securities Act of 1933 or until the registration
statement shall become effective on such date as the commission, acting
pursuant to said Section 8(a), may determine."
The Company will file an amendment to the above referenced registration
statement upon receipt of comments, if any, from the Staff to incorporate such
comments, if any, and to furnish the required information with respect to
selling shareholders. If there are any other questions, please direct them to
the undersigned or to Joseph M. Berl of our Washington office at 301-347-3100.
Very truly yours,
/s/ Suzanne J. Roberts
Suzanne J. Roberts
For POWELL, GOLDSTEIN, FRAZER & MURPHY LLP
cc: Joseph M. Berl, Esq.
