PENNY AUCTION SOLUTIONS, INC.
330 A. Street, Suite 156
San Diego, CA 92101
September 6, 2013
VIA EDGAR
Securities and Exchange Commission
Division of Corporate Finance
100 F. Street, N.E.
Washington, D.C. 20549
Re:Penny Auction Solutions, Inc. Application For Withdrawal on Form RW pursuant to Rule 477 of the Securities Act of 1933, as amended, Registration Statement on Form 10 (File No.000-55004)
Pursuant to Rule 477 promulgated under the Securities Act of 1933, as amended (the“Securities Act”), Penny Auction Solutions, Inc. (the“Company”) hereby respectfully request the withdrawal, effective as of the date hereof or at the earliest practicable date hereafter, of its Registration Statement on Form 10 (File No.000-55004), together with all exhibits thereto, initially filed with the Securities and Exchange Commission (the“Commission”) onJuly 11, 2013 (collectively, the“Registration Statement”).
The Company believes that withdrawal of the Registration Statement is consistent with the public interest and the protection of investors, as contemplated by Rule 477(a) under the Securities Act.The Company is withdrawing the Registration Statement to avoid the automatic effectiveness of the Registration Statement sixty days after its initial filing beforethe Company has had an opportunity to fully respond to the comments of the Commission staff.The Company intends to re-file the Form 10 oncethe Company has fully responded to the comments of the Commission Please note the Registration Statement was a voluntary filing under Section 12(g) of the Securities Exchange Act of 1934, as amended.
It is our understanding that this application for withdrawal of the Registration Statement will be deemed granted as of the date that it is filed with the Commission unless, within fifteen days after such date, the Company receives notice from the Commission that this application will not be granted. Please send copies of the written order granting withdrawal of the Registration Statement to Michael Holt at the abovementioned address, facsimile number (866) 275-5260, with a copy to Greg Carney, Indeglia & Carney, 1299 Ocean Avenue, Suite 450, Santa Monica, CA 90401, facsimile number (310) 458-8007.
If you have any questions with respect to this matter, please contact Greg Carney, Indeglia & Carney at (310) 982-2720.
Sincerely, | |
PENNY AUCTION SOLUTIONS, INC. | |
/s/ Michael Holt Michael Holt | |
Chief Executive Officer |