December 10, 1999
Securities and Exchange Commission
Division of Corporation Finance
Office of Small Business Review
450 5th Street NW - Room 3112
Mail Stop 0304
Washington, DC 20549
Attn: Barbara Jacobs, Deputy Chief
RE: S.M.A. Real Time Inc.
Registration Statement on Form SB-2
File No. 333-82581
Dear Ms. Jacobs:
As counsel for S.M.A. Real Time Inc., we respectfully request withdrawal of
the above captioned registration.
The withdrawal request is being made because Dirks & Company, Inc., as
representative of the underwriters, has informed S.M.A. that it would not be
able to achieve sufficient sales of the registered securities to satisfy the
firm commitment requisites necessary for a closing.
We wish to convey our sincere thanks to the SEC staff for the extremely
knowledgable and courteous assistance with respect to this registration.
Very truly yours,
STEPHEN M. ROBINSON, P.A.
By: Stephen M. Robinson
SMR:cab
encls.
cc: Nasdaq-Amex Market Group - Attn: Robert J. McCormick
Senior Analyst Listing Qualifications
National Association of Securities Dealers, Inc. -
Attn: Paul Russell
Orrick Herrington & Sutcliffe - Attn: Michael Zeidel, Esq.
S.M.A. Real Time Inc. - Attn: Michael Morrissey, President
