Ted Weitzman
                                                             310.552.5057
                                                             Fax: 310.552.5001
                                                             tweitzman@kl.com






June 11, 2001




VIA EDGAR AND COURIER

Mr. John Reynolds
Special Counsel Assistant Director
Office of Small Business
450 Fifth Street, N.W.
Washington, DC  20549

     Re:  Advanced Optics Electronics Inc. - Registration Statement on Form SB-2
          File Number 333-51056
          Request for Withdrawal

Dear Mr. Reynolds:

Advanced Optics  Electronics  Inc. (the "Company")  hereby makes  application to
withdraw its  Registration  Statement on Form SB-2,  File Number  333-51056 (the
"Registration  Statement"),  relating to its common stock,  par value $0.001 per
share (the "Common  Stock"),  pursuant to Rule 477 under the  Securities  Act of
1933, as amended.

The  Registration  Statement  was  originally  filed  on  December  1,  2000 and
Amendment No. 1 thereto was filed on April 25, 2001. The Registration  Statement
has not been declared effective.  The Registrant is requesting withdrawal of the
Registration Statement due to the Registrant's inability at this time to proceed
with an offering of the securities being registered  thereby. No securities were
issued or sold pursuant thereto and the Registrant never printed nor distributed
a preliminary  prospectus.  Accordingly,  we request that an order  granting the
withdrawal  of the  Registration  Statement  be  issued  by the  Securities  and
Exchange Commission as soon as possible.

If you have any questions regarding this matter, please contact the undersigned
at (310) 552-5000.

Sincerely,

/S/ TED WEITZMAN

Ted Weitzman

cc:      Amanda Gordon
         Don Rinehart
         Ed Evangelida
         Al Pavot
         Leslie S. Robins
         John Cousins
         Leib Orlanski, Esq.