<PAGE>
[VIEWLOCITY, INC. LETTERHEAD]
January 9, 2001
VIA EDGAR
---------
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: Mr. James Lopez
Re: Viewlocity, Inc.: Application to Withdraw Registration Statement on
Form S-1, as amended (File No. 333-43568), and Registration
Statement on Form 8-A (File No. 000-31707)
Ladies and Gentlemen:
Pursuant to Rule 477 of the Securities Act of 1933, as amended (the
"Securities Act"), Viewlocity, Inc. (the "Company") hereby applies for an
order granting withdrawal of its registration statement on Form S-1, together
with all amendments and exhibits thereto, Commission File No. 333-43568
(collectively, the "Registration Statement"). The Registration Statement was
originally filed with the Securities and Exchange Commission (the
"Commission") on August 11, 2000.
At this time, due to the volatility of the public capital markets, the
Company has determined not to proceed with the public offering contemplated
by the Registration Statement. The Company did not print or distribute any
preliminary prospectuses, nor has the Company offered or sold any securities
under the Registration Statement and all activity in pursuit of the public
offering has been discontinued.
In addition, the Company hereby applies for an order granting withdrawal
of its registration statement on Form 8-A, including all exhibits thereto,
Commission File No. 000-31707 (the "8-A Registration Statement"), filed by
the Company with the Commission on October 5, 2000, pursuant to the
Securities Exchange Act of 1934, as amended (the "Exchange Act"), in
connection with the public offering contemplated by the Registration
Statement.
Accordingly, we request an order granting the withdrawal of the
Registration Statement and the 8-A Registration Statement be issued by the
Commission as soon as possible. Please provide the Company a dated copy of
the order, or orders, granting such withdrawal, which shall state "Withdrawn
upon the request of the registrant, the Commission consenting thereto," and
include the order or orders in the files for the Registration Statement and
the 8-A Registration Statement.
If you have any questions regarding this request for withdrawal, please
contact David M. Calhoun, Esq. of Morris, Manning & Martin, L.L.P., at
(404) 233-7000.
Respectfully,
VIEWLOCITY, INC.
/s/ Stan F. Stoudenmire
Stan F. Stoudenmire
Senior Vice President and Chief Financial Officer
