COMMERX INC
RW, 2000-10-20
BUSINESS SERVICES, NEC
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                                 [Letterhead]



                               October 20, 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)
        Amended 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 nor will be
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            Statement, stating "Withdrawn upon the request of the registrant,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/ Tim J. Stojka


                                                Tim J. Stojka
                                                Chief Executive Officer


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