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IMAGENETIX, INC.
16935 W. Bernardo Drive, Suite 101
San Diego, CA 92127
(858) 674-8455
January 13, 2000
Richard Wulff, Chief
Office of Small Business Review
Division of Corporation Finance
U.S. Securities and Exchange Commission
Washington, D.C. 20549
Re: Imagenetix, Inc. (the "Company")
Form SB-1
File No. 333-87535
Dear Mr. Wulff:
Pursuant to Rule 477(a) of Regulation C, the Company hereby applies for
an order granting the immediate withdrawal of its registration statement on
Form SB-1 (File No. 333-87535), together with all exhibits and amendments
thereto. The registration statement was originally filed with the Securities
and Exchange Commission on September 22, 1999, and amended on November 24,
1999, December 22, 1999, January 13, 2000, and January 25, 2000.
The reason for the request for withdrawal is the inability of the Company
to obtain clearance from the NASD for the compensation to be paid to the
underwriter in the offering. The Company had proposed to offer and sell
233,334 shares of its common stock to the public for $3.00 per share. The
offering was to have been underwritten by Spencer Edwards on a firm
underwriting basis. No securities have been sold under the registration
statement and no selling efforts were made by the underwriter. No
preliminary prospectuses were delivered to prospective investors by the
underwriter or the Company.
Accordingly, we hereby request that an order granting withdrawal of the
registration statement be issued by the Securities and Exchange Commission as
soon as possible.
Sincerely,
/s/ William Spencer, President
cc: Ronald N. Vance, Esq.
Michael Clampitt, Reviewer
Jon Sawyer, Esq.
Grant Hardy, CPA
