First Ecom.com, Inc.
902, Henley Building 5
Queen's Road Central
Hong Kong SAR
December 17, 1999
VIA EDGAR
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: First Ecom.com, Inc.
Registration Statement on Form 10
(File No. 0-27753)
Ladies and Gentlemen:
The above-referenced registration statement was filed with the Securities and
Exchange Commission by First Ecom.com, Inc. on October 21, 1999. It will
automatically become effective on December 20, 1999 in accordance with Section
12(g) of the Securities Exchange Act of 1934. Inasmuch as the staff has not
completed their review of the registration statement, they have requested that
the registrant withdraw it before it becomes effective on the grounds that the
withdrawal would be consistent with the public interest. Accordingly, the
registrant hereby applies to withdraw the above-referenced registration
statement before it becomes effective.
The registrant will refile the registration statement immediately and will
request acceleration of its effective date as soon as the staff have completed
their review.
Please provide the Company with a copy of the order granting withdrawal of the
Registration Statement as soon as it is available.
If you have any questions regarding this application, please contact the
Company's legal counsel, D. Roger Glenn (212\588-5511) or Marc A. Berger
(212\588-5515) of Goodman Phillips & Vineberg.
Very truly yours,
FIRST ECOM.COM, INC.
/s/ JOHN R. BREWER
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John R. Brewer, Secretary
