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GOMEZ, INC.
55 OLD BEDFORD ROAD
LINCOLN, MA 01773
October 19, 2000
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Judiciary Plaza
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: Gomez, Inc. (formerly, Gomez Advisors, Inc.)
Registration Statement on Form S-1 (Registration No. 333-35182)
Dear Ladies and Gentlemen:
Pursuant to Rule 477(a) promulgated under the Securities Act of 1933, as
amended, Gomez, Inc. (formerly, Gomez Advisors, Inc.) (the "Registrant")
hereby respectfully requests that the Securities and Exchange Commission
consent to the withdrawal of its Registration Statement on Form S-1
(Registration No. 333-35182), together with all exhibits and amendments
thereto (the "Registration Statement"). The Registrant is requesting such
withdrawal because of unfavorable market conditions that would adversely
affect the offering of the shares of common stock, par value $0.0001 per
share, covered by the Registration Statement. No securities were sold or will
be sold under the Registration Statement.
The Registrant further requests that, pursuant to Rule 477(c), an order
with the date of the granting of the withdrawal be included in the file for
the above-captioned Registration Statement in the following manner:
"Withdrawn upon the request of the Registrant, the Commission consenting
thereto."
Please address any questions you may have to Lewis J. Geffen, Esquire,
at Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., One Financial Center,
Boston, Massachusetts 02111, telephone number (617) 542-6000, facsimile
number (617) 542-2241.
Thank you for your assistance with this matter.
GOMEZ, INC.
By: /s/ Frederic G. Hammond
------------------------
Frederic G. Hammond
Vice President, Business
Affairs and General
Counsel
cc: Lewis J. Geffen, Esquire
MINTZ, LEVIN, COHN, FERRIS, GLOVSKY AND POPEO, P.C.
Richard Vilsoet, Esquire
SHEARMAN & STERLING
