HOLLINGER INC.
10 Toronto Street
Toronto
Ontario Canada, M5C 2B7
416.363.8721
December 20, 2004
Securities and Exchange Commission
450 Fifth Street
Washington, D.C. 20549
Re: Hollinger Inc. Application for Withdrawal of Registration
Statement on Form F-4 (File No. 333-106587) (the "Registration
Statement")
Ladies and Gentlemen:
Hollinger Inc. ("Hollinger") hereby applies for withdrawal of the
Registration Statement pursuant to Rule 477 under the Securities Act of 1933, as
amended. As a result of current circumstances, Hollinger does not expect in the
near term to be able to commence and complete the exchange offer contemplated by
the Registration Statement. No securities were sold in connection with the
Registration Statement. By execution of this letter below, Ravelston Management
Inc. and 504468 N.B. Inc., the other two registrants under the Registration
Statement, hereby join in this application for withdrawal of the Registration
Statement.
Please call John J. O'Brien (212-558-3944) or Sara A. Cohen
(212-558-1625), of Sullivan & Cromwell LLP, if you have any questions relating
to this application.
Securities and Exchange Commission -2-
Very truly yours,
HOLLINGER INC.
By: /s/ Peter G. White
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Name: Peter G. White
Title: Vice President, Operations
and Secretary
RAVELSTON MANAGEMENT INC.
By: /s/ Peter G. White
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Name: Peter G. White
Title: Executive Vice President
504468 N.B. Inc.
By: /s/ Peter G. White
---------------------------------------
Name: Peter G. White
Title: Executive Vice President
cc: Katherine Hsu
Max A. Webb
(Division of Corporation Finance)