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Broadview Networks Holdings, Inc.
September 6, 2000
VIA FACSIMILE AND EDGAR
Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.
Washington D.C. 20549
Re: Broadview Networks Holdings, Inc. (Registration No. 333-96391)
Application for Withdrawal
Ladies and Gentlemen:
Pursuant to Rule 477(a) promulgated under the Securities Act of 1933,
as amended, Broadview Networks Holdings, Inc., a Delaware corporation (the
"Registrant") hereby applies for an order granting the immediate withdrawal of
its Registration Statement on Form S-1, File No. 333-96391, together with
exhibits thereto, filed with the Securities and Exchange Commission on February
8, 2000 (the "Registration Statement").
Pursuant to the Registration Statement, the Registrant proposed to
register for sale approximately $161,000,000 of its common stock, $0.01 par
value per share, for issuance to the public. The Registrant believes that
current market conditions make proceeding with this offering inadvisable. No
securities have been sold under the Registration Statement. Accordingly, we
hereby request that an order granting withdrawal of the Registration Statement
be issued by the Securities and Exchange Commission as soon as possible.
Please do not hesitate to contact the undersigned at (718) 707-8800, or
Thomas M. Vitale, Esq. of Mayer, Brown & Platt at 212-506-2500, should you have
any questions regarding this matter.
Very truly yours,
/s/ Vern M. Kennedy
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Chief Executive Officer
