1
                                                              June 18, 2001


Via Edgar Transmission

Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.

Washington, D.C. 20549

Re: Cupertino Electric, Inc. - Request to Withdraw Registration Statement on
    Form S-1 (File No. 333-52538) - Originally Filed on December 22, 2000
    ---------------------------------------------------------------------------

Ladies and Gentlemen:

      Cupertino Electric, Inc. (the "Company")hereby requests, pursuant to Rule
477 of Regulation C of the Securities Act of 1933, as amended (the "Securities
Act"), that the registration statement on Form S-1, including all exhibits
thereto(File No. 333-52538), filed by the Company with the Securities and
Exchange Commission (the "Commission") on December 22, 2000(the "Registration
Statement")be withdrawn effective immediately. The Company is withdrawing the
Registration Statement because of unfavorable market conditions. There was no
circulation of preliminary prospectuses in connection with the proposed
offering, the Registration Statement was not declared effective by the
Commission, and none of the Company's securities were sold pursuant to the
Registration Statement.

      The Company paid the filing fee for the Registration Statement by
electronic wire transfer to the account of the Commission at the time of the
initial filing, and the Company understands that such fee may be offset against
the total filing fee due for a subsequent registration statement filed prior to
December 22, 2005.

      The Company may undertake a subsequent private offering in reliance on
Rule 155(c) of the Securities Act.

      The Company requests that the Commission consent to this application on
the grounds that the withdrawal of the Registration Statement is consistent with
the public interest and the protection of investors, as contemplated by
paragraph (a) of Rule 477.

      Please provide the Company a facsimile copy of the order consenting to the
withdrawal of the Registration Statement as soon as it is available. The
facsimile number of the Company is (408) 275-6987.

      If you have any questions regarding this request for withdrawal, please
contact Maria L. Pizzoli, Farella Braun + Martel LLP, counsel for the Company,
at (415) 954-4400.

                                            Sincerely,

                                            /s/ James S. Ryley
                                            -----------------------------
                                            James S. Ryley
                                            Chief Executive Officer and
                                            President


Cc: Daniel Horwood, Securities and Exchange Commission
    Paul E. Hurlburt, Nasdaq Stock Market, Inc.
    Sean P. Dineen, Bank of America Securities
    Peter T. Healy, O'Melveny & Myers LLP