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MEDIBUY.COM, INC.
10120 PACIFIC HEIGHTS BLVD.
SAN DIEGO, CA 92121
July 25, 2000
VIA FACSIMILE AND EDGAR TRANSMISSION
U.S. Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W., Mail Stop 4-9
Washington, D.C. 20549
Attn: Ms. Paula Dubberly
RE: MEDIBUY.COM, INC.
REGISTRATION STATEMENT ON FORM S-4 (FILE NO. 333-33172)
REQUEST FOR WITHDRAWAL
Dear Ms. Dubberly:
Pursuant to Rule 477 of the Securities Act of 1933, as amended (the "Securities
Act"), medibuy.com, Inc. (the "Registrant") hereby requests withdrawal of its
Registration Statement on Form S-4 (SEC File No. 333-33172) filed with the
Commission on March 23, 2000 (the "Registration Statement"). In order to
facilitate the fast and efficient consummation of the Registrant's pending
acquisitions and the integration of those businesses, the Registrant has
determined it is not in its best interests to proceed with the Registration
Statement at this time. We also confirm by this letter that no securities have
been issued or sold pursuant to the Registration Statement.
If you should have any questions regarding this application, please contact
Barbara L. Borden or Larry W. Nishnick of Cooley Godward LLP at (858) 550-6000.
Sincerely,
MEDIBUY.COM, INC.
By: /s/ NORMAN R. FARQUHAR
-----------------------
Norman R. Farquhar
Executive Vice President, Chief Financial
Officer and Secretary
cc: Suzanne Hayes, Securities & Exchange Commission
Marcia Brown, Nasdaq - Amex Market Group
Dennis J. Murphy
Jeremy D. Glaser, Esq.
Dennis A. Calderon, Esq.
Barbara L. Borden, Esq.
Carl R. Sanchez, Esq.
Frank H. Golay, Jr., Esq.
Robert A. Miller, Jr., Esq.
