<PAGE>
eCommercial.com, Inc.
95 Enterprise, Suite 360
Aliso Viejo, CA 92656
February 7, 2000
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
RE: eCommercial.com, Inc.
Registration Statement on Form 10
(File No. 0-28403)
Ladies and Gentlemen:
The above referenced registration statement was filed with the Securities and
Exchange Commission by eCommercial.com, Inc. on December 7, 1999 and would have
become effective by operation of the statute on February 7, 2000 in accordance
with Section 12(g) of the Securities Act of 1934. Inasmuch as the staff has
asked for extensive revisions, they have suggested that the registrant withdraw
the registration before it becomes effective and submit a revised registration
statement in response to such comments. Accordingly, the registrant hereby
withdraws the above referenced registration statement before it becomes
effective.
The registrant will re-file the registration statement 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 Chief Financial Officer, Michael R. Friedl (949-916-8705), or Kevin A.
Coyle (9160-930-3200) of Gray Cary Ware & Freidenrich LLP.
Very truly yours,
eCommercial.com, Inc.
/s/ Michael R. Friedl
Chief Financial Officer