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[LETTERHEAD OF TRADEOUT.COM]
January 16, 2001
VIA EDGAR AND FACSIMILE
Securities and Exchange Commission
450 5th Street, NW
Washington, D.C. 10549
Attn: Mark Webb
Re: TradeOut, Inc.
Registration Statement on Form S-1
Registration No. 333-32602
Ladies and Gentlemen:
This letter is filed pursuant to Rule 477 of the Rules and Regulations
under the Securities Act of 1933, as amended, with reference to the
Registration Statement on Form S-1, Registration No. 333-32602 (together with
all exhibits and amendments, the "Registration Statement"), that was
originally filed with the Securities Exchange Commission on March 15, 2000.
In light of current market conditions, the Registrant has determined not to
effect the initial public offering to which the Registration Statement
relates at this time. No securities have been sold pursuant to the
Registration Statement. Accordingly, the Registrant hereby applies for an
order granting the immediate withdrawal of the Registration Statement.
TradeOut, Inc.
By: /s/ James Mooney 1/16/01
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James Mooney
President and Chief Executive
Officer
