UPAY, INC.
3010 LBJ Freeway
12th Floor
Dallas, Texas 75234
(972) 888-6052
November 8, 2019
FILED AS CORRESPONDENCE VIA EDGAR
Securities and Exchange Commission
100 F Street, N. W.
Washington, D.C. 20549
| Re: | UPAY, Inc. |
| Registration Statement on Form S-1, Registration No. 333-212447 |
Ladies and Gentlemen:
Pursuant to Rule 477 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), UPAY, Inc. (the “Registrant” ), the Registrant filed a Form RW on November 7, 2019 (“Form RW”) requesting that the Securities and Exchange Commission (the “Commission”) consent to the withdrawal of its Registration Statement on Form S-1 (File No. 333-212447), together with all exhibits thereto, initially filed on July 8, 2016 as subsequently amended and declared effective on December 6, 2016 (collectively the “Registration Statement”).
The Registrant hereby withdraws the Form RW.
Please contact our legal counsel, Frederick M. Lehrer, Esquire of Frederick M. Lehrer, P. A. at (561) 706-7646 or flehrer@securitiesattorney1.com with any questions regarding this matter.
/s/ Jaco Folscher
Jaco Folscher
Chief Financial Officer
