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[G.I. Joe's Letterhead]
April 20, 1999
Securities and Exchange Commission
450 Fifth Street
Washington, DC 20549
RE: G.I. JOE's, INC.
APPLICATION TO WITHDRAW REGISTRATION STATEMENT
Dear Sir or Madam:
On behalf of G.I. Joe's, Inc., an Oregon corporation (the "Company"), I
hereby request that the Company's Registration Statement (File No. 333-61527)
filed on Form S-1, including all amendments thereto (the "Registration
Statement"), be withdrawn from registration pursuant to Rules 477 and 478 of
Regulation C promulgated under the Securities Act of 1933, as amended.
The Company has decided to withdraw the Registration Statement because the
terms on which the underwriters said they could proceed with the offering were
unacceptable to the Company.
I look forward to receiving your consent to the withdrawal of the
Registration Statement at your earliest convenience. If you have any comments
or questions relating to this application to withdraw, please call Patrick J.
Simpson at (503) 727-2035.
Sincerely yours,
/s/ Norman P. Daniels
Norman P. Daniels
Chief Executive Officer, President and
Chairman of the Board
cc: Stacey Kramer
Todd Bauman
Patrick J. Simpson
