<PAGE> 1
WEBSIDESTORY, INC.
October 10, 2000
VIA FACSIMILE AND EDGAR
Securities and Exchange Commission
Mailstop 0409
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: Suzanne Hayes
Re: Request for Withdrawal of Registration Statement on Form S-1, File
Number 333-34976 (the "Registration Statement")
Dear Ms. Hayes:
WebSideStory, Inc. (the "Company") hereby makes application to withdraw the
Registration Statement relating to its common stock, par value $0.002 per share
(the "Common Stock"), pursuant to Rule 477 under the Securities Act of 1933, as
amended. In light of current unfavorable market conditions, the Company has
decided not to proceed with a public offering of its Common Stock. The Company
represents that no securities have been sold under the Registration Statement
and all activity in pursuit of the public offering has been discontinued.
Accordingly, we request an order granting the withdrawal of the
Registration Statement be issued by the Securities and Exchange Commission as
soon as possible. Should you have any questions regarding this matter, please
contact our attorney, Jeffrey T. Baglio, at 858-677-1458.
Very truly yours,
WebSideStory, Inc.
By: /s/ John J. Hentrich
-------------------------
John J. Hentrich
President and Chief Executive Officer
cc: Pamela Sussman, Nasdaq National Stock Market
Cameron Jay Rains, Esq., Gray Cary Ware & Freidenrich LLP
Jeffrey T. Baglio, Esq., Gray Cary Ware & Freidenrich LLP
Bruce R. Hallet, Esq., Brobeck, Phleger & Harrison LLP
Scott R. Santagata, Esq., Brobeck, Phleger & Harrison LLP
<PAGE> 2
WEBSIDESTORY, INC.
October 10, 2000
VIA FACSIMILE AND EDGAR
Securities and Exchange Commission
Mailstop 0409
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: Suzanne Hayes
Re: Request for Withdrawal of Confidential Treatment Application (the
"Confidential Treatment Application") Relating to Exhibits Filed with
Registration Statement on Form S-1, File Number 333-34976 (the
"Registration Statement")
Dear Ms. Hayes:
WebSideStory, Inc. (the "Company") hereby makes application to withdraw the
Confidential Treatment Application relating to certain exhibits filed with the
Registration Statement. In light of current unfavorable market conditions, the
Company has decided not to proceed with a public offering of its common stock.
The Company represents that no securities have been sold under the Registration
Statement and all activity in pursuit of the public offering has been
discontinued.
Accordingly, we request an order granting the withdrawal of the
Confidential Treatment Application be issued by the Securities and Exchange
Commission as soon as possible. Should you have any questions regarding this
matter, please contact our attorney, Jeffrey T. Baglio, at 858-677-1458.
Very truly yours,
WebSideStory, Inc.
By: /s/ John J. Hentrich
-------------------------
John J. Hentrich
President and Chief Executive Officer
cc: Pamela Sussman, Nasdaq National Stock Market
Cameron Jay Rains, Esq., Gray Cary Ware & Freidenrich LLP
Jeffrey T. Baglio, Esq., Gray Cary Ware & Freidenrich LLP
Bruce R. Hallet, Esq., Brobeck, Phleger & Harrison LLP
Scott R. Santagata, Esq., Brobeck, Phleger & Harrison LLP
