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[Letterhead of Mercata, Inc.]
January 2, 2001
Via Edgar
Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.
Washington, DC 20549
Re: Mercata, Inc.
CIK: 1089484
Commission File No. 333-32078 Application for Withdrawal
Ladies and Gentlemen:
Pursuant to Rule 477(a) promulgated under the Securities Act of 1933, as
amended, Mercata, Inc., a Delaware corporation (the "Registrant") hereby applies
for an order granting the immediate withdrawal of its Registration Statement on
Form S-1, together with all exhibits and amendments thereto, Commission File No.
333-32078 (collectively, the "Registration Statement"). The Registration
Statement was originally filed with the Securities and Exchange Commission (the
"Commission") on March 9, 2000.
Pursuant to the Registration Statement, the Registrant proposed to register
certain shares of its Common Stock, $0.001 par value per share (the "Shares"),
for issuance to the public with a proposed maximum offering price of
$100,000,000. Based upon changed circumstances regarding the securities markets,
the Registrant has determined at this time not to pursue the initial public
offering of equity securities pursuant to the Registration Statement.
Furthermore, no securities have been sold under the Registration Statement.
Accordingly, we request an order granting the withdrawal of the Registration
Statement be issued by the Commission as soon as possible.
If you have any questions regarding the foregoing application for withdrawal,
please contact Christopher W. Wright or Matthew D. Latimer of Cooley Godward
LLP, legal counsel to the Registrant in connection with the Registration
Statement, at (425) 893-7700.
Sincerely,
Mercata, Inc.
/s/ Tom Van Horn
Tom Van Horn
President & CEO
cc: H. Christopher Owings, Securities and Exchange Commission
John Dalton Clopper, Securities and Exchange Commission
Thomas S. Choe - Nasdaq Stock Market, Inc.
Christopher W. Wright, Esq., Cooley Godward LLP
Scott L. Gelband, Esq., Perkins Coie LLP
Patrick Devine, Esq., Perkins Coie LLP
