BIOLABS INC
RW, 1999-12-23
MEDICAL LABORATORIES
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                           [GRAPHIC -- COMPANY LOGO]

                                 BioLabs, Inc.



October 6, 1999

VIA ELECTRONIC MAIL

Securities & Exchange Commission
450 Fifth Street, NW
Washington, DC
USA  20549


To Whom It May Concern:

The undersigned small business issuer,  having filed a Form 10-SB, on August 13,
1999,  and an Amendment  thereto on Form  10-SB(g)/A,  hereby elects to withdraw
such prior pending filing.

The undersigned intends to immediately refile a new Form 10-SB(g), responsive to
comments received from the staff.

An additional copy of this letter is also being provided to the staff.

Very truly yours,

BioLabs, Inc.

By: /s/Lawrence J. Pasemko
    ----------------------
    Lawrence J. Pasemko

Title: Secretary/Treasurer


cc: Mr. Robert T. Hall
    Via Telecopier: (202) 942-9527




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