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                               [ATS Letterhead]

June 21, 2001



VIA EDGAR TRANSMISSION
AND OVERNIGHT COURIER

Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.
Washington, D.C.  20549
Attn:  Michael K. Ferraro

                Re:     Advanced Thermal Sciences Corporation
                        Registration Statement on Form S-1 (File No. 333-44384)

Dear Mr. Ferraro:

     Pursuant to Rule 477 of the Securities Act of 1933, as amended, Advanced
Thermal Sciences Corporation ("ATS") hereby (i) applies for an order granting
the immediate withdrawal of its Registration Statement on Form S-1 (Securities
and Exchange Commission (the "Commission") File No. 333-44384), together with
all exhibits and amendments thereto (collectively, the "Registration
Statement"), and (ii) requests the return of all materials previously filed with
the Commission pursuant to Confidential Treatment Requests.  The Registration
Statement was originally filed on August 23, 2000, and was amended on September
29, 2000, October 10, 2000, October 18, 2000 and December 12, 2000.

     Based upon changed circumstances in the securities markets, ATS has
determined at this time not to pursue the initial public offering contemplated
by the Registration Statement.  None of ATS' securities have been sold under the
Registration Statement.

     ATS hereby respectfully requests that an order granting the withdrawal of
the Registration Statement be issued by the Commission as soon as possible.

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     Please forward copies of the order consenting to the withdrawal of the
Registration Statement to the undersigned at Advanced Thermal Sciences
Corporation, 3355 East La Palma Avenue, Anaheim, CA  92806 and to Bryn Jedlic
at Shearman & Sterling, 555 California Street, San Francisco, CA  94104.

     If you have any questions regarding this application, please contact Bryn
Jedlic of Shearman & Sterling at (415) 616-1188.


                                        Very truly yours,
                                        ADVANCED THERMAL SCIENCES
                                        CORPORATION

                                        /s/ Bruce Thayer
                                        -------------------------------------
                                        Bruce Thayer
                                        President and Chief Operating Officer


BJ/jm
cc:     Rohan S. Weerasinghe, Esq.
        Victor A. Hebert, Esq.