ImClone Systems Incorporated
180 Varick Street
New York, New York 10014
(212) 645-1405
December 22, 2000
VIA EDGAR AND FACSIMILE
Securities and Exchange Commission
450 5th Street, N.W.
Washington, D.C. 10549
Attention: Andrew Thorpe
Re: ImClone Systems Incorporated
Registration Statement on Form S-3
File No. 333-49578
Ladies and Gentlemen:
This letter is filed pursuant to Rule 477 of the Rules and Regulations
under the Securities Act of 1933, as amended, with reference to the Form S-3
Registration Statement No. 333-49578, together with all exhibits thereto (the
"Registration Statement") that was originally filed with the Securities and
Exchange Commission on November 9, 2000. The Registrant has determined not to
proceed with the Registration Statement because it does not intend to raise
capital at this time. No securities have been sold pursuant to the Registration
Statement. Accordingly, the Registrant hereby applies for an order granting
immediate withdrawal of the Registration Statement.
IMCLONE SYSTEMS INCORPORATED
By: /s/ Catherine M. Vaczy
----------------------------
Catherine M. Vaczy
Vice President, Legal and
Associate General Counsel
