JAMES N. BARBER Attorney at Law Suite 100, Bank One Tower 50 West Broadway Salt Lake City, UT 84101 Telephone: (801) 364-6500 Fax: (801) 364-3406 or (801) 532-3535 E-Mail: Barberjn@aol.com July 9, 1999 Steven Duvall, Assistant Director Division of Corporation Finance Securities and Exchange Commission Washington, D.C. 20549-0404 Re: Txon International Development Corporation/Form 10-SB Dear Mr. Duvall: This letter is occasioned by the receipt by Txon of a comment letter over the signature of Tim Levinberg of your Division related to Txon's Form 10-SB filed May 18, 1999. We appreciate the timely response of your division to this filing. As a result of the filing date, the 60 day comment period will pass before Txon will be able to address the comments made by Mr. Levinberg. Accordingly, Txon hereby withdraws its aforesaid Form 10-SB filing pending resolution of the pending comments. This letter is countersigned by John Chris Kirch, an officer of the corporation authorized to take this action. Thank you for your cooperation in this matter. Very truly yours, /s/James N. Barber James N. Barber Attorney for Txon International Development Corp. Countersigned: TXON INTERNATIONAL DEVELOPMENT CORPORATION /s/ John Chris Kirch By: John Chris Kirch, Chairman & Director of Corporate Development