KENNETH M. CHRISTISON ATTORNEY AT LAW 51 PARTIDGE DRIVE NOVATO, CA 94945 TELEPHONE: 	415-898-6829 FACSIMILE:	415-898-7519 October 31, 1999 Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 	Re: Topaz Group, Inc.: File No. 0-27415 Dear Madam or Sir: 	On behalf of Topaz Group, Inc. (the "Company"), I hereby request withdrawal of the Form 10 Registration Statement, File No. 0-27415, filed September 22, 1999. The Company intends to re-file its Form 10 at such time as necessary changes have been made to assure the Company's financial statements comply with the SEC Regulation S-X Rule 2-02. 	Please call me at 415-898-6829 if there are any questions. 							Very truly yours, 							Kenneth M. Christison 							Attorney for Topaz Group, Inc. ccs: 	Topaz Group, Inc. 	John Klopper, Esq. Div of Corp. Finance