SHIMODA RESOURCES HOLDINGS, INC.


June 20, 2003


John Reynolds, Assistant Director
Office of Small Business
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

Re:      Shimoda Resources Holdings, Inc.
         Reg. Statement on Form SB-2
         File No. 333-90978
         Filed June 21, 2002


Dear Mr. Reynolds,

Pursuant to the  requirements  of Rule 477 under the  Securities Act of 1933, as
amended,  Shimoda Resources Holdings,  Inc. (the "Company") hereby requests that
the Securities and Exchange  Commission ("SEC") consent to the withdrawal of the
Company's Registration Statement on Form SB-2 (File No. 333-90978) filed on June
21st, 2002 (the "Registration Statement").

The  Company  is  withdrawing  the  Registration  Statement  because it has been
informed that the Company does not qualify as a small  business  issuer since it
is deemed to be an "investment company", as defined under the Investment Company
Act of 1940. The  Registration  Statement has not been declared  effective,  and
none of the  Company's  securities  were sold in  connection  with the  offering
previously contemplated to be made under the Registration Statement.

Please  forward  copies  of  the  order  consenting  to  the  withdrawal  of the
Registration  Statement to the undersigned at Shimoda Resources Holdings,  Inc.,
15 River  Road,  Suite  230,  Wilton,  Connecticut  06897-4065.  If you have any
questions regarding this letter, please contact me directly. Very truly yours,

 /s/ David J. Mapley
- --------------------
David J. Mapley
CEO

CC: W. Barnett, Esq., E. Purple, Esq.







          15 River Road, Suite 230, Wilton, Connecticut 06897-4065 USA
                       Tel: 203-563-9430 Fax: 203-563-9832
                            www.shimodaresources.com