NIDA & MALONEY, LLP
800 Anacapa Street
Santa Barbara, CA 93101
Telephone: (805) 568-1151
Facsimile: (805) 568-1955
August 8, 2000
Via Edgar
Securities and Exchange Commission
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549
Re: GenesisIntermedia.com, Inc.
Registration Statement on Form 424B
File No. 333-41120 (the "Registration Statement")
Ladies and Gentlemen:
As counsel to GenesisIntermedia.com, a Delaware corporation (the
"Registrant"), we hereby make application to withdraw the above-referenced
Registration Statement pursuant to Rule 477 under the Securities Act of 1933, as
amended.
We submit this request as we inadvertently filed the Registration Statement
as a 424(b)(1) and it should have been a 424(b)(3). The Registrant is
concurrently filing the final form of prospectus under Rule 424(b)(3).
Should you need any additional information or have any questions regarding
the above, please contact me at (805) 884-8127.
Very truly yours,
Nida & Maloney, LLP
By: /s/ Theodore R. Maloney
________________________
Theodore R. Maloney
