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PROCURENET, INC.
2 MADISON ROAD
FAIRFIELD, NEW JERSEY 07004
November 10, 2000
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
ProcureNet, Inc.
Withdrawal of Registration Statement
on Form S-1 (Reg. No. 333-42562)
Ladies and Gentlemen:
ProcureNet, Inc. ("PROCURENET") hereby requests, pursuant to Rule 477(a)
under the Securities Act of 1933, as amended, that the Registration Statement on
Form S-1 (Reg. No. 333-42562), filed by ProcureNet with the Securities and
Exchange Commission (the "COMMISSION") on July 28, 2000 (the "REGISTRATION
STATEMENT"), be withdrawn. The Registration Statement was filed with the
Commission in connection with a proposed initial public offering of shares of
the common stock of ProcureNet. However, ProcureNet has determined that market
conditions are not favorable for an initial public offering at this time.
Please do not hesitate to call me at (973) 575-6620 should you have any
questions concerning the Registration Statement or this letter.
Sincerely yours,
/s/ John D. Sanford
John D. Sanford
Vice President and Chief Financial Officer
cc: John Mahon
Securities and Exchange Commission
E. Raman Bet-Mansour, Esq.
Debevoise & Plimpton
William F. Schwitter, Esq.
Paul, Hastings, Janofsky & Walker LLP