1 Securities and Exchange Commission Division of Corporation Finance 450 5th Street, NW Washington, D.C. 20549 Attention: Mr. Jeff Minton Mail Stop 4-7 Re: ICO-Teledesic Global Limited New ICO Global Communications (Holdings) Limited Request Under Rule 477 for Withdrawal of Registration Statement on Form S-4 (File Nos. 333-46230/46230-1) Dear Mr. Minton: I am the Chief Executive Officer of ICO-Teledesic Global Limited and New ICO Global Communications (Holdings) Limited (the "CO-Registrants"). Pursuant to Commission Rule 477, and due to internal developments as well as developments in the capital markets, on behalf of the Co-Registrants I hereby request that the Registration Statement on Form S-4, as amended (File Nos. 333-46230/46230-1) be withdrawn from further consideration by the Commission. No securities were sold in connection with the offering. Sincerely, Greg Clarke Chief Executive Officer ICO-Teledesic Global Limited New ICO Global Communications (Holdings) Limited