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[Wilson Sonsini Goodrich & Rosati Letterhead]
December 30, 1998
VIA EDGAR, FACSIMILE AND COURIER
Ms. Rani Doyle, Esq.
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Mail Stop 4-6
Telephone: 202.942.1834
Facsimile: 202.942.9544
RE: MOMENTUM BUSINESS APPLICATIONS, INC.
REGISTRATION STATEMENT ON FORM S-1
REGISTRATION NO. 333-67363
Dear Ms. Doyle:
On behalf of Momentum Business Applications, Inc. ("Momentum"), and
pursuant to Rule 477 under the Securities Act of 1933, as amended, we hereby
request that Momentum's registration statement on Form S-1 (Registration No.
333-67363), originally filed on November 16, 1998 and amended on November 25,
1998 (the "Registration Statement"), be withdrawn. Momentum is withdrawing
the Registration Statement because it has decided to register its Class A
Common Stock with a registration statement on Form 10 (Registration No.
000-25185), originally filed on December 24, 1998 and amended on December 29,
1998.
In addition, Momentum herby requests that its related registration
statement on Form 8-A also be withdrawn at this time.
If you have any questions in this regard, please contact Steven L.
Berson, Peter Heinecke or the undersigned of Wilson Sonsini Goodrich & Rosati,
Professional Corporation, at (650) 493-9300.
Very truly yours,
WILSON SONSINI GOODRICH & ROSATI
Professional Corporation
/s/ Michael S. Russell
Michael S. Russell
cc: Ronald E.F. Codd
