<PAGE>
[Moai Letterhead]
December 6, 2000
BY EDGAR
--------
Securities and Exchange Commission
Division of Corporate Finance
Attention: Mr. Robert T. Hall
Ms. Letty Lynn
Judiciary Plaza
450 Fifth Street, N.W.
Washington, D.C. 20549-1004
Moai Technologies, Inc.
Registration Statement on Form S-1, SEC File No. 333-34676
----------------------------------------------------------
Dear Mr. Hall and Ms. Lynn:
On behalf of Moai Technologies, Inc. (the "Company"), this letter is
filed pursuant to Rule 477 under the Securities Act of 1933, with respect to the
Registration Statement on Form S-1, SEC File No. 333-34676, which was filed on
April 13, 2000 (the "Registration Statement").
In light of current market conditions, the Company has determined not to
proceed with the public offering contemplated by the Registration Statement. No
securities have been sold pursuant to the Registration Statement. Accordingly,
the Company hereby requests that an order granting the withdrawal of the
Registration Statement be issued by the Securities and Exchange Commission as
soon as possible.
Sincerely,
Moai Technologies, Inc.
By: /s/ Philip Smith
-----------------------------------
Philip N. Smith, Vice President of
Finance and Chief Financial Officer
