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[Letterhead of Asia Online, Ltd.]
September 26, 2000
VIA EDGAR AND FEDERAL EXPRESS
Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.
Washington, DC 20549
Attention: Suzanne Hayes
Re: Asia Online, Ltd.
CIK: 00001093954
Commission File No. 333-42902 Application for Withdrawal
Ladies and Gentlemen:
Pursuant to Rule 477(a) promulgated under the Securities Act of 1933, as
amended, Asia Online, Ltd. (the "Registrant") hereby applies for an order
granting the immediate withdrawal of its Registration Statement on Form S-1,
together with all exhibits thereto, Commission File No. 333-42902 (collectively,
the "Registration Statement"). The Registration Statement was originally filed
with the Securities and Exchange Commission (the "Commission") on August 2,
2000.
Based upon changed circumstances in 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 Brandon Fields or Kevin Galligan of Cooley Godward LLP, legal
counsel to the Registrant in connection with the Registration Statement, at
(303) 546-4000.
Sincerely,
Asia Online, Ltd.
/s/ Kevin Randolph
Kevin Randolph
President and Chief Executive Officer
cc: Marcia Brown - Nasdaq Stock Market, Inc.
Michael L. Platt, Esq.
Brandon Fields, Esq.
Kevin Galligan, Esq.
Paul Gross, Esq.
