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[IMX LETTERHEAD]
May 30, 2000
VIA EDGAR AND OVERNIGHT COURIER
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Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: IMX Exchange, Inc.
Registration Statement on Form S-1
File No. 333-31958
Ladies and Gentlemen:
Pursuant to Rule 477 under the Securities Act of 1933, IMX Exchange, Inc. (the
"Company") hereby requests the withdrawal of the Company's Registration
Statement on Form S-1, File No. 333-31958 (the "Registration Statement"). The
Company has elected not to proceed with the offering due to general market
conditions and a determination that it would not be in the Company's best
interest to proceed at this time. No offers or sales of the Company's common
stock were made pursuant to the Registration Statement.
Should you have any questions regarding this matter, please contact Paul
Blumenstein of Gray Cary Ware & Freidenrich at 650-833-2238, or Jeffrey A.
Pullen, our Chief Financial Officer, at 925-983-2000.
Sincerely,
/s/ RICHARD E. WILKES
Richard E. Wilkes
President and Chief Executive Officer
cc: John Saia, Securities and Exchange Commission
Marcia Brown, The Nasdaq Stock Market
Paul A. Blumenstein, Gray Cary Ware & Freidenrich LLP
