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[Letterhead]
October 13, 2000
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549
Re: Commerx, Inc.
Registration Statement on Form S-1 (SEC File No. 333-95387)
Application for Withdrawal Pursuant to Rules 477 and 478
Ladies and Gentlemen:
Pursuant to Rule 477(a) and (c) and Rule 478(c) of the Securities Act of
1933, as amended, Commerx, Inc. (the "Company") hereby applies for withdrawal of
the registration statement on Form S-1 (File No. 333-95387) and all exhibits
thereto filed with the Securities and Exchange Commission (the "Commission") on
January 26, 2000 (the "Registration Statement"). The Company has determined to
request withdrawal because of unfavorable market conditions. None of the
securities covered by the Registration Statement have been sold.
The Company further requests:
1. That the Commission find that the withdrawal hereby requested is
consistent with the public interest and the protection of investors;
and
2. That an order with the date of granting of this withdrawal be
included in the files of the Commission for the Registration
Statement, stating "Withdrawn upon the request of the registrant,
the Commission consenting thereto."
In order for us to confirm the granting of such order, please fax a copy
of such order to Charles C. Kim, counsel to the Company, at (312) 201-2555.
Very truly yours,
COMMERX, INC.
/s/ David Dill
David Dill
SVP, CFO