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GREENMOUNTAIN.COM COMPANY
55 Green Mountain Drive
South Burlington, Vermont 05403
May 8, 2000
VIA EDGAR TRANSMISSION
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: GreenMountain.com Company
Registration Statement on Form S-1
(Registration No. 333-75171)
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Ladies and Gentlemen:
In accordance with Rule 477 under the Securities Act of 1933, as
amended, GreenMountain.com Company, a Delaware corporation (the "Company"),
hereby requests that the Company's Registration Statement on Form S-1, including
all amendments thereto (collectively, the "Registration Statement"), be
withdrawn as discussed by telephone between Renee Fried of the Staff and Troy B.
Lewis of Jones, Day, Reavis & Pogue, counsel to the Company, on May 8, 2000.
The Registration Statement was filed with the Securities and Exchange
Commission for the purpose of registering shares of common stock, par value
$0.01 per share, of the Company in connection with the Company's proposed
initial public offering. As a result of market conditions, the Company ceased
all activities in connection with the proposed public offering in late June
1999. The Company did not withdraw the Registration Statement at that time in
the hope that market conditions would change so as to allow the Company to
recommence and successfully complete the proposed public offering. However, as
of the date hereof, no such change in market conditions has occurred, and the
Company does not anticipate such a change will occur in the immediate future.
Accordingly, the Company has determined to withdraw the Registration Statement
at this time.
The Company requests that the Commission grant, at the Staff's
earliest convenience, an order approving this application.
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Please contact John T. McCafferty or Troy B. Lewis of Jones, Day,
Reavis & Pogue, at 214.969.4854 and 214.969.3721, respectively, should you have
any questions regarding this request.
Sincerely,
/s/ PETER H. ZAMORE
Peter H. Zamore,
Vice President, General Counsel and
Secretary
cc: Renee Fried
Securities and Exchange Commission
John T. McCafferty
Troy B. Lewis
Jones, Day, Reavis & Pogue
