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MERL Holdings Inc.com
1230 Parkway Avenue - Suite 311
Ewing, NJ 08628
MERL Holdings, Inc.com
July 18, 2000
United States Securities and
Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: Susann Reilly, Esq.
Re: MERL Holdings, Inc.com
Form 10-SB
File No. 1-15921
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Dear Ms. Reilly:
Please accept this letter as a request to withdraw the Form 10-SB
filing for MERL Holdings, Inc.com noted with the above file number. The reason
for the withdrawal is that we have not completed our discussions with the staff
concerning issues raised by the Assistant Director of the Division of
Corporation Finance in his comment letter of June 14, 2000. Because of the sixty
day time period, it is requested that the application be withdrawn. The Form
10-SB will be re-submitted on the Edgar System in its entirety upon completion
of these discussions and changes required thereby. We appreciate your
cooperation in this matter and look forward to the re- submission of the Form
10-SB for our company.
Very truly yours,
MERL Holdings, Inc.com
By: /s/ Ed Johnson
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Ed Johnson, Chairman and CEO