New SAC
                              c/o Maples & Calder
                                P.O. Box 309GT
                                 Ugland House
                              South Church Street
                           George Town, Grand Cayman
                                Cayman Islands








VIA EDGAR AND FACSIMILE

March 28, 2002

Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C.  20549
Attn:    Ms. Sara Hirsch
         Mr. Craig Olinger

         Re:      Application for withdrawal under Rule 477(a) by New SAC,
                  Seagate Technology International and the Subsidiary
                  Guarantors listed in the Registration Statement on
                  Form S-4 (File No. 333-59328)

Ladies and Gentlemen:

Pursuant to Rule 477(a) promulgated under the Securities Act of 1933, as
amended (the "Securities Act"), New SAC, Seagate Technology International and
the subsidiary guarantors (the "Subsidiary Guarantors" and, together with New
SAC and Seagate Technology International, the "Registrants" or "we") listed in
the Registration Statement on Form S-4, Commission File No. 333-59328 (the
"Registration Statement"), hereby apply for an order granting the immediate
withdrawal of the Registration Statement, together with all exhibits and
amendments thereto. The Registration Statement was originally filed with the
Securities and Exchange Commission (the "Commission") on April 20, 2001 and
was amended on April 27, 2001.

Pursuant to the Registration Statement, the Registrants proposed to register
an exchange offer (the "Exchange Offer") involving (i) the issuance by Seagate
Technology International of $210 million in aggregate principal amount of its
12 1/2% senior subordinated notes (the "Exchange Notes"), which were to be
offered in exchange for $210 million in aggregate principal amount of its 12
1/2% senior subordinated notes that were privately placed pursuant to Rule
144A and Regulation S (the "Outstanding Notes") and (ii) the issuance by New
SAC and the Subsidiary Guarantors of guarantees of the Exchange Notes, which
were to be offered by them in exchange for their guarantees of the Outstanding
Notes.




In a letter to the Registrants dated May 15, 2001, the staff of the Commission
expressed its view that, as a result of option plans that prevent most of the
Subsidiary Guarantors from being wholly-owned by New SAC, the Subsidiary
Guarantors are unable to rely on the relief provided by Rule 3-10(d) of
Regulation S-X. Through communications in writing, over the telephone and in
person with the staff of the Commission over the past year, we have sought to
find a way to provide the financial information requested by the staff of the
Commission. Because we do not believe we can, as a practical matter, comply
with the requirements of Rule 3-10(a) of Regulation S-X as it applies to the
Exchange Offer, we have determined at this time not to pursue the Exchange
Offer.

Accordingly, we request an order granting the withdrawal of the Registration
Statement be issued by the Commission as soon as possible. It is our
understanding that the request will be deemed granted at the time of this
filing, unless we receive notice from the Commission that the request will not
be granted within 15 days from filing. No securities have been sold under the
Registration Statement.

We hereby advise the Commission that we may undertake a subsequent private
offering of debt securities that would be issued by a subsidiary of New SAC.
To the extent that Rule 155(c) of the Securities Act is applicable thereto,
any such offering would be done in reliance on and in accordance with that
rule.

Should you have any questions regarding the foregoing application for
withdrawal, please contact William H. Hinman, Jr., at (650) 251-5120, or Karen
M. King, at (650) 251-5155, of Simpson Thacher & Bartlett, our legal counsel
in connection with the Registration Statement.


                                         Very truly yours,

                                         /s/ William L. Hudson

                                         William L. Hudson
                                         Senior Vice President, General Counsel
                                         and Corporate Secretary of New SAC



cc:      William H. Hinman, Jr., Simpson Thacher & Bartlett



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