Jenkens & Gilchrist Parker Chapin LLP AUSTIN, TEXAS THE CHRYSLER BUILDING (512) 499-3800 405 LEXINGTON AVENUE CHICAGO, ILLINOIS NEW YORK, NEW YORK 10174 (312) 425-3900 DALLAS, TEXAS (212) 704-6000 (214) 855-4500 FACSIMILE (212) 704-6288 HOUSTON, TEXAS (713) 951-3300 www.jenkens.com LOS ANGELES, CALIFORNIA Mitchell S. Nussbaum (310) 820-8800 (212) 704-6426 SAN ANTONIO, TEXAS mnussbaum@jenkens.com (210) 246-5000 WASHINGTON, D.C. (202) 326-1500 October 2, 2001 EDGAR Coding: Type: RW Sequence: 1 Description: Request for Withdrawal Via EDGAR --------- Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549-0405 Attention: John H. McCreery/H. Christopher Owings Re: The Topaz Group, Inc. Form 10 filed August 3, 2001 File No. 0-27415 Dear Mr. McCreery: On behalf of The Topaz Group, Inc. (the "Company"), we hereby request that the Company's Registration Statement on Form 10 (the "Form 10") be withdrawn. The Company believes that it may be unable to complete its responses to your letter dated September 20, 2001 with respect to the Form 10 prior to the Form 10 becoming automatically effective on October 3, 2001. The Company requests that this withdrawal take effect immediately or as soon thereafter as is practicable. The Company intends to file a new Form 10 as soon as it is able to complete its responses to your letter. Should you have any questions or require additional information regarding the foregoing, please contact the undersigned at Tel: 212-704-6426 or Terrance C. Cuff, Chief Financial Officer at Tel: 425-392-3144. Sincerely, /s/ Mitchell S. Nussbaum Mitchell S. Nussbaum cc: Jeremy F. Watson Terrance C. Cuff Yvette Y. Chang