Niche Pharmaceuticals, Inc.
                                  P.O. Box 449
                                   200 N. Oak
                                Roanoke, TX 76262
                                 (817) 491-2770


                                                       January 8, 1998

Via Edgar

Securities and Exchange Commission
450 Fifth Street N.W.
Judiciary Plaza
Washington, D.C. 20549

                  Re:  Form SB-2, Registration No. 333-17767

Gentlemen:

                  Pursuant to Rule 477  promulgated  under the Securities Act of
1933, as amended, Niche Pharmaceuticals, Inc. (the "Company") hereby applies for
the withdrawal of its  registration  statement filed on Form SB-2,  Registration
No. 333-17767 (the "Registration Statement").

                  The Company makes this application for withdrawal  because the
Company's proposed underwriter has advised the Company that it will be unable to
proceed  with  the  underwriting  covered  by the  Registration  Statement.  The
Registration Statement was not declared effective by the Securities and Exchange
Commission,  and,  accordingly,  no  securities  covered  by  such  Registration
Statement have been sold by, or on behalf of, the Company or any other person.

                                             Very truly yours,

                                             NICHE PHARMACEUTICALS, INC.


                                             By: /s/ Stephen F. Brandon
                                                Stephen F. Brandon, President