February 11, 2000
Attn: Mr. Jeffrey Riedler
Assistant Director
Division of Corporation Finance
United States Security Exchange Commissions
450 Fifth Street, N.W.
Washington, D.C. 20549
Via facsimile and U.S. Mail
(202) 942-9533
RE: Termination of SB-2 Filing
SEC file #333-91835
Dear Mr. Riedler,
Please allow this letter to serve as our request to withdraw the pending
SB-2 filing, SEC file #333-91835. The filing is being withdrawn due to the fact
that we have terminated our investment agreement with Swartz Equity.
Accordingly, the purpose for the filing no longer exists.
Very truly yours,
/s/DANIEL W. BIVINS, JR.
Daniel W. Bivins, Jr.
Sr. Vice President and
General Counsel
cc: Paul C. Pershes
Joel Mayersohn