ISE Labs, Inc. 2095 Ringwood Avenue San Jose, CA 95131 December 10, 1998 VIA EDGARLINK TRANSMISSION - -------------------------- Securities and Exchange Commission 450 Fifth Street, N.W. Judiciary Plaza Washington, D.C. 20549 ATTN: Peggy A. Fisher Assistant Director RE: ISE LABS, INC. - REGISTRATION STATEMENT ON FORM S-1 (REGISTRATION NO. 333-49685) Ladies and Gentlemen: On behalf of ISE Labs, Inc. (the "Company"), I hereby request the above-referenced Registration Statement, originally filed with the Commission on April 8, 1998 and amended on May 21, 1998, June 3, 1998, June 11, 1998 and June 12, 1998, be withdrawn. The Company is requesting withdrawal of the Registration Statement due to financial market conditions. The Company has not sold nor made any offers to sell any of the shares covered by such Registration Statement. Please provide the Company with a copy of the order granting withdrawal of the Registration Statement as soon as it is available. If you have any questions regarding this application, please do not hesitate to contact the undersigned at (650) 496-2887 or, in his absence, Michael C. Doran at (650) 812-2443. Very truly yours, /s/ Warren T. Lazarow ---------------------------------- Warren T. Lazarow Secretary ISE Labs, Inc. cc: Pamela Long, Esq. Christopher J. Gregoire Saeed A. Malik. Jeffrey D. Saper, Esq. Mike Ackrell Charles Nelson