WEBVALLEY INC
RW, 1999-07-21
BUSINESS SERVICES, NEC
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                                  July 21, 1999

Via EDGAR and facsimile

Securities and Exchange Commission
450 Fifth Street N.W.
Judiciary Plaza

Washington, D.C. 20549

     Re: FORM R-W
         WebValley, Inc.
         Registration Statement on Form S-1 filed on April 8, 1999
         File No.: 333-75943

Dear Ladies/Gentlemen:

     WebValley, Inc. (the "Company") hereby requests, in accordance with Rule
477 of Regulation C promulgated under the Securities and Exchange Act of 1933,
as amended, that the Commission permit the Company to withdraw its Registration
Statement on Form S-1 filed with the Commission on April 8, 1999 (File No.
333-75943).

     The Company has decided that it no longer desires to become a public
company at this time or in the foreseeable future.

     We appreciate the Staff's prompt attention to this request. If any member
of the Staff has any questions concerning this request please contact the
Company's counsel, Jeffrey C. Anderson at (612) 343-3958 or Jennifer C. Debrow
at (612) 335-7861.

                                       Sincerely,

                                       WEBVALLEY, INC.

                                                /s/ Satya P. Garg
                                       -----------------------------------
                                       Satya P. Garg
                                       President and Chief Executive Officer

GP:614719 v1


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