ANTS SOFTWARE COM INC
RW, 2000-01-05
COMMERCIAL PHYSICAL & BIOLOGICAL RESEARCH
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                             NIDA & MALONEY, LLP
                               800 Anacapa Street
                            Santa Barbara, CA 93101
                            Telephone (805) 568-1151


                                 January 5, 2000


Via Edgar

Securities and Exchange Commission
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549

         Re:      Ants Software.com
                  Registration Statement on Form 8-A
                  File No. 333-93973 (the "Registration Statement")

Ladies and Gentlemen:

         As special  counsel to Ants  Software.com,  a Nevada  corporation  (the
"Registrant"),  we hereby  make  application  to withdraw  the  above-referenced
Registration Statement pursuant to Rule 477 under the Securities Act of 1933, as
amended.

     We submit this  request as the  Registration  Statement  was  inadvertently
filed prior to its completion.

         Should  you  need any  additional  information  or have  any  questions
regarding the above, please contact me at (805) 884-8127.

                         Very truly yours,

                         Nida & Maloney, LLP


                         By: /s/ Theodore R. Maloney
                             ---------------------------
                                 Theodore R. Maloney


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