MENTON PROMOTIONS INC
RW, 2001-01-16
BUSINESS SERVICES, NEC
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                             Mentor Promotions, Inc.

                         892 Stegar Town Drive, Suite 34
                              Rockwall, Texas 75032
                                 (972) 772-7740



January 11, 2001

Mr. Letty G. Lynn
Ms. Kara A. Sandler
U.S. Securities & Exchange Commission
450 Fifth Street NW
Washington, DC 20549-0305


RE:      Mentor Promotions, Inc.
         Form SB-1
         File No. 333-47588


Dear Mr. Lynn and Ms. Sandler:


         In response to your comment  letter dated  November 7, 2000,  we do not
believe we should be classified as a blank check company, and because we believe
the amount of time and expense  necessary to comply with your  comments in order
not to be so  classified  will be greater than our  benefit,  we have decided to
withdraw the Mentor Promotions,  Inc. Registration  Statement on Form SB-1, File
No. 333-47588.

         I have filed this response on EDGAR. Please let me know if I need to do
anything further.


Sincerely,


/s/  Mark Wells
-----------------
     Mark Wells





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