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ZeBu
595 Market Street, 6th Floor
San Francisco, CA 94105
June 13, 2000
MAIL STOP 0406
The Securities and Exchange Commission
450 Fifth Street
Washington, D.C. 20549
Attn: Jennifer Ours
Division of Corporation Finance
RE: REGISTRATION STATEMENT ON FORM S-1
(REGISTRATION NO. 333-31440 OF ZEBU)
Pursuant to Rule 477 promulgated under the Securities Act of 1933, Zebu
("the Company") respectfully requests consent to withdraw its Registration
Statement on Form S-1 (Registration No. 333-31440) originally filed March 1,
2000. The Company does not intend to pursue a public offering of its common
stock at this time.
Sincerely,
/s/Steven H. Gerber
Steven H. Gerber
President