VIA EDGAR
April 12, 2000
Securities and Exchange Commission
450 5th Street, N.W.
Washington, D.C. 20549
RE: Commtouch Software Ltd. Registration Statement on Form F-1
(No. 333-31836)--Application to Withdraw Registration Statement
Dear Sir or Madam:
The undersigned is the agent for service named in the above
registration statement.
Commtouch Software Ltd. hereby respectfully requests, under Securities
Act Rules 477 and 478, that the Commission withdraw the above registration
statement and all amendments thereto.
The Company has decided to withdraw the registration statement because
it believes that it would not be advisable to proceed with the offering under
current market conditions.
I look forward to receiving your consent to the withdrawal of the
registration statement at your earliest convenience. If you have any comments or
questions relating to this appplication, please call the undersigned at (408)
653-4360 or Lior O. Nuchi, Esq., the Company's counsel, at (415) 393-2310.
Sincerely,
/s/ James E. Collins
James E. Collins
Chief Financial Officer
