SPORTSTRAC SYSTEMS, INC.
Suite 100, 6654 Gunpark Drive
Boulder, CO 80301
Phone: (303) 527-0600
Fax: (303) 527-1661
June 14, 2000
Via Edgar and Overnight Delivery
Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street N.W.
Washington, D.C. 20549
RE: SportsTrac Systems, Inc.
Registration Statement on Form SB-2
Filed July 15, 1999
File No. 333-82885
Ladies and Gentlemen:
Pursuant to Rule 477 of Regulation C of the Securities Act of 1933, as
amended, SportsTrac Systems, Inc. ("Registrant") hereby applies to the
Securities and Exchange Commission (the "Commission") for consent to withdraw
the referenced Registration Statement on Form SB-2 (the "Registration
Statement"), such withdrawal to be effective as of the date hereof or at the
earliest practical date thereafter. As grounds for this application, Registrant
has determined that it will not proceed with the registration and sale of the
Units of Common Stock and Warrants as contemplated in the Registration
Statement. Registrant's management thus believes that withdrawal of the
Registration Statement is appropriate and consistent with the public interest
and the protection of investors as contemplated by Rule 477(a).
The Registrant confirms that no securities were offered or sold pursuant to
the Registration Statement, that the Commission did not declare the Registration
Statement effective, and that no preliminary prospectuses were circulated.
Please provide the Registrant with a copy of the order consenting to the
withdrawal of the Registration Statement as soon as it is available. The
facsimile number of the Registrant is (303) 527-1661. If you have any questions,
please contact Registrant's counsel, William F. Riggs, at (918) 591-5226 (fax
918-591-5360).
Sincerely,
SportsTrac Systems, Inc.
By: /s/ Marc R. Silverman
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Marc R. Silverman, President
cc: Alison Toledo; Mail Stop 3-4
