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LeadersOnline, Inc.
18401 Von Karman, Suite 500
Irvine, California 92612
(949) 752-1000
September 25, 2000
VIA EDGAR AND OVERNIGHT DELIVERY
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Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549
Re: LeadersOnline, Inc.
Registration Statement on Form S-1 (Registration No. 333-34390)
Application for Withdrawal
Ladies and Gentlemen:
Pursuant to Rule 477(a) of the Securities Act of 1933, as amended,
LeadersOnline, Inc., a Delaware corporation (the "Registrant"), hereby
respectfully applies to the Securities and Exchange Commission for an order
granting the immediate withdrawal of its Registration Statement on Form S-1
(Registration No. 333-34390), as filed on April 10, 2000, together with all
amendments thereto (the "Registration Statement").
As set forth in the Registration Statement, the Registrant proposed to
register shares of its Class A common stock, par value $0.001 per share (the
"Shares"), in connection with an initial public offering. The Registrant,
however, does not believe that the terms available in the public market at this
time are sufficiently favorable to warrant proceeding with or completing an
initial public offering of the Shares. No Shares have been sold under the
Registration Statement and the Registrant does not currently intend to pursue
any further activities in connection with an initial public offering of the
Shares.
If the Staff of the Securities and Exchange Commission has any questions
regarding this application for withdrawal, please feel free to contact the
undersigned at (949) 752-1000 or Ronald S. Beard, Esq. of Gibson, Dunn &
Crutcher LLP at (949) 451-3800.
Sincerely,
LeadersOnline, Inc.,
a Delaware corporation
By: /s/ Michael T. Christy
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Michael T. Christy
Chief Executive Officer
cc: Securities and Exchange Commission
David M. Lynn and Kim M. Mazur
