ESPERNET COM INC
RW, 2000-01-13
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                               espernet.com, inc.
                              383 West 12th Street
                               New York, NY 10014
                                Tel: 212-989-4706
                                Fax: 212-989-4717


                                               January 13, 2000


VIA EDGAR

Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W., Mail Stop 4-6
Washington, D.C.  20549
Attention:  Ms. Kathleen Krebs

          Re:  espernet.com, inc.
               Registration Statement on Form S-1
               File No. 333-88153

Ladies and Gentlemen:

     Pursuant  to Rule  477(a)  under the  Securities  Act of 1933,  as amended,
espernet.com, inc.  hereby   respectfully   requests   the   withdrawal  of  the
Registration  Statement on Form S-1 of  espernet.com, inc.,  File No.  333-88153
(the "Registration Statement").

     The reason for the requested  withdrawal of the  Registration  Statement is
that the  public  offering  of common  stock  contemplated  in the  Registration
Statement has been terminated because of adverse market conditions.

     Upon the grant of the Commission's  consent to the requested  withdrawal of
the  Registration  Statement,  please return a dated copy of the order  granting
such withdrawal to the undersigned.

                                               Very truly yours,

                                               espernet.com, inc.


                                               By:   /s/ Martin D. Prazak
                                                     Martin D. Prazak
                                                     President and Chief
                                                     Executive Officer




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