VIRTUAL REALITY INC/
RW, 2000-07-18
BUSINESS SERVICES, NEC
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                                                         July 18, 2000

VIA ELECTRONIC TRANSMISSION

Mr. Richard K. Wulff
Chief, Office of Small Business
Securities and Exchange Commission
Washington, D.C. 20549

         Re:      Virtual Reality, Inc. - Registration Statement on Form 10-SB
                  Commission File No. 0-30699; Filed May 24, 2000
                  ------------------------------------------------------------

Dear Mr. Wulff:

     Pursuant  to Rule 477  promulgated  under the  Securities  Act of 1933,  as
amended,  Virtual Reality, Inc. (the "Company") hereby applies for withdrawal of
the  above-referenced  registration  statement on Form 10-SB (the  "Registration
Statement")  originally  filed with the Securities and Exchange  Commission (the
"Commission") on May 24, 2000.

     The Company  requests such  withdrawal  because of the  termination  of the
proposed  acquisition of  Intellashop,  Inc.  Furthermore,  such withdrawal will
allow the Company to fully  revise the  Registration  Statement  and  accurately
respond to the Commission's preliminary comments.

     The  Company  respectfully  requests  that the  Commission  consent  to the
withdrawal of the registration statement,  effective as of the earliest possible
date.


                                                Very truly yours,

                                                VIRTUAL REALITY, INC.


                                                By:      /s/  Martin F. Cardone
                                                    ----------------------------
                                                       Martin F. Cardone, C.E.O.


cc:  Steven A. Sanders, Esq.


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