<PAGE>
THE NEW YORK TIMES COMPANY
229 WEST 43rd STREET
NEW YORK, NY 10036
RHONDA L. BRAUER (212) 556-7127
Assistant Secretary
and Senior Counsel FAX NUMBER:
(212) 556-4634
[email protected]
December 8, 2000
Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, N.W.
Washington, DC 20549-0405
Re: THE NEW YORK TIMES COMPANY'S REGISTRATION STATEMENT ON FORM S-3
FILED MAY 19, 1998
FILE NO.: 333-53007
Ladies and Gentlemen:
Pursuant to Rule 477 of Regulation C of the Securities Act of 1933, as
amended, The New York Times Company (the "Registrant") hereby requests the
withdrawal of its Registration Statement on Form S-3, as filed with the
Securities and Exchange Commission (the "Commission") on May 19, 1998 (File No.:
333-53007) (the "Registration Statement").
Registrant initially filed the Registration Statement to register 185,000
shares of its Class A Common Stock, par value $0.01. These shares were issuable
upon the exercise of nonqualified stock options granted under Registrant's
Non-Employee Directors' Stock Option Plan (the "Plan") that were transferable by
the original optionees. Although Registrant had previously registered shares
under the Plan on Form S-8, Form S-8 was not available at that time for
registration of stock issued to the transferee of a transferable option. Thus,
Registrant filed the Registration Statement to cover the exercise of any such
transferred options. No such options have been exercised by the transferees
through the date hereof.
In February 1999, the Commission amended Form S-8 (Release No. 33-7646;
February 25, 1999). As a result, registration under Form S-8 is now sufficient
to meet Registrant's registration requirements.
Please acknowledge the Commission's consent to Registrant's request for
withdrawal of the Registration Statement by entering an order for the withdrawal
of the Registration Statement in the Commission's file for the Registration
Statement. Please feel free to contact me at 212-556-7127 if you have any
questions or comments.
Sincerely,
The New York Times Company
By: /s/ Rhonda L. Brauer
-----------------------------------------
Rhonda L. Brauer
Assistant Secretary and Senior Counsel
