Carl P. Ranno
                             2816 East Windrose Dr.
                                Phoenix, Arizona
                                  602 493 0369
                                Fax 602 493 5119

June 1, 2001

Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549

     Re: Accord Advanced Technologies, Inc.
         Form SB-2 Registration Statement - File Number 333-46878

Dear Sir or Madam,

     Pursuant  to Rule 477 under the  Securities  Act of 1933,  as  amended,  we
hereby apply on behalf of Accord Advanced Technologies,  Inc. (the "Registrant")
to  withdraw  Form SB-2  Registration  Statement  filed with the  Commission  on
September 28, 2000. The Registrant is applying for such  withdrawal  because the
Form SB-2  Registration  Statement is no longer  applicable to the company and a
new  Registration  Statement  will be filed in the near future which will better
serve the Registrant's needs.

     Thank you for your  anticipated  assistance in this matter.  Please contact
the  undersigned  with any questions  concerning  this  application at (602) 493
0369.

                                   Sincerely,

                                   /s/ Carl P. Ranno
                                   Carl P. Ranno