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BREAKAWAY SOLUTIONS, INC.
350 ROWES WHARF
BOSTON, MASSACHUSETTS 02110
April 14, 2000
VIA EDGAR
Securities and Exchange Commission
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549
Re: Breakaway Solutions, Inc.
Registration Statement on Form S-1
(REGISTRATION NO. 333-33468)
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Ladies and Gentlemen:
In accordance with Rule 477(a) promulgated under the Securities Act
of 1933, as amended, Breakaway Solutions, Inc. (the "Registrant") hereby
respectfully requests that the Securities and Exchange Commission consent to
the withdrawal of its Registration Statement on Form S-1 (Registration No.
333-33468), together with all exhibits thereto (the "Registration
Statement"). The Registrant is requesting such withdrawal because of
unfavorable market conditions that would adversely affect the offering of the
shares of common stock, par value $.000125 per share, covered by the
Registration Statement. No shares of the Registrant's common stock have been
issued or sold under the Registration Statement.
The Registrant further requests that, pursuant to Rule 477(c), an
order with the date of the granting of the withdrawal be included in the file
for the Registration Statement in the following manner: "Withdrawn upon the
request of the Registrant, the Commission consenting thereto."
If you have any questions with respect to this letter, please call
the undersigned at (617) 960-3400 or Thomas L. Barrette, Jr. of the law firm
of Hale and Dorr LLP at (617) 526-6000.
Sincerely,
BREAKAWAY SOLUTIONS, INC.
By: /s/ Gordon Brooks
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Name: Gordon Brooks
Title: President and Chief Executive
Officer
cc: Mr. Thomas L. Barrette, Jr., Esq.
