Worldwide Petromoly, Inc.
                       12600 Deerfield Parkway, Suite 100
                              Alpharetta, GA 30004


May 9, 2002

Via Edgar Transmission and Courier

Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.
Washington, D.C. 20549

           Re: Worldwide Petromoly, Inc.; Application for Withdrawl of
               Registration Statement on Form SB-2;
               Registration File No. 333-70176

Ladies and Gentlemen:

         Worldwide Petromoly, Inc. (the "Company"),  hereby requests pursuant to
Rule 477 of Regulation C of the Securities Act of 1933, as amended,  to withdraw
from  registration  the  registration  statement  on Form  SB-2,  including  all
amendments and exhibits  thereto (the  "Registration  Statement")  (Registration
Statement No. 333-70176),  filed by the Company with the Securities and Exchange
Commission (the "Commission") on September 26, 2001. The Registration  Statement
is being  withdrawn  because  of  unfavorable  market  conditions.  There was no
circulation  of  preliminary   prospectuses  in  connection  with  the  proposed
offering,   the  Registration  Statement  was  not  declared  effective  by  the
Commission,  and none of the  Company's  securities  were sold  pursuant  to the
Registration Statement.

         The Company requests that the Commission consent to this application on
the grounds that the withdrawal of the Registration Statement is consistent with
the  public  interest  and the  protection  of  investors,  as  contemplated  by
paragraph (a) of Rule 477.

         Please provide the Company a facsimile copy of the order  consenting to
the  withdrawal of the  Registration  Statement as soon as it is available.  The
facsimile should be sent to (404) 812-3101.

         If you have any questions regarding this request for withdrawal, please
contact Gerry Balboni of Baker,  Donelson,  Bearman & Caldwell,  counsel for the
Company, at (404) 812-3111.

                                   Sincerely,

                                   /s/ Daniel W. Hollis
                                   --------------------
                                   Daniel W. Hollis
                                   Chief Executive Officer