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December 4, 2000
Division of Corporate Finance VIA EDGAR AND FACSIMILE
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: Naviant, Inc.
Registration Statement on Form S-1
File No. 333-32126
Ladies and Gentlemen:
Pursuant to Rule 477(a) promulgated under the Securities Act of 1933,
as amended, Naviant, Inc. (the "Registrant") hereby applies for an order
granting the immediate withdrawal of its Registration Statement on Form S-1,
File No. 333-32126, together with all exhibits and amendments thereto (the
"Registration Statement"). The Registration Statement was originally filed with
the Securities and Exchange Commission on March 10, 2000.
The Registrant believes that the terms obtainable in the marketplace
at this time are not sufficiently attractive to warrant proceeding with the sale
of the shares of the Registrant's Common Stock, and that completing a
discretionary financing on unfavorable terms would not be in the best interests
of the Registrant or its stockholders at this time. No securities have been
sold under the Registration Statement and no activity in pursuit of this
offering has taken place since May 1, 2000. Accordingly, we hereby request that
an order granting the withdrawal of the Registration Statement be issued by the
Securities and Exchange Commission as soon as possible.
If you have any questions regarding this matter, please do not
hesitate to contact the undersigned at (610) 355-7040 or Kevin J. Lavin, Esq. of
Brobeck, Phleger & Harrison LLP at 202-220-5242.
Very truly yours,
NAVIANT, INC.
By: /s/ Charles W. Stryker
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Charles W. Stryker
Chairman and Chief Executive Officer
cc: Robert L.R. Munden, Esq.
Kevin J. Lavin, Esq.
Julia K. Cowles, Esq.
