IBX GROUP, INC. 350 JIM MORAN BOULEVARD DEERFIELD BEACH, FL 33442 (954) 312-1660 April 27, 2005 VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance 450 Fifth Street, N.W. Washington, D.C. 20549 RE: IBX GROUP, INC. REGISTRATION STATEMENT ON FORM SB-2 FILED ON OCTOBER 13, 2004 FILE NO. 333-114180 Ladies and Gentlemen: Pursuant to Rule 477(a) under the General Rules and Regulations under the Securities Act of 1933, as amended (the "SECURITIES ACT"), please consider this correspondence as an application to the United States Securities and Exchange Commission (the "COMMISSION") for an order permitting IBX Group, Inc. (the "REGISTRANT") to withdraw its Registration Statement on Form SB-2, filed by the Registrant on October 13, 2004 (the "REGISTRATION STATEMENT"). No securities were sold in connection with the Registration Statement. The Registrant further requests that all fees paid to the Commission in connection with the filing of the Registration Statement be credited for future use in accordance with Rule 457(p) of the Securities Act. Accordingly, the Registrant hereby respectfully requests that, in accordance with the provisions of Rule 477(a) under the Securities Act, an Order granting the withdrawal of the Registration Statement be issued by the Commission as soon as reasonably possible. If you have any questions or comments regarding the foregoing application for withdrawal, please contact Clayton E. Parker, Esq., legal counsel to the Registrant, at 305-539-3300. Please provide a copy of the Order consenting to this withdrawal to Mr. Parker by facsimile at 305-358-7095. Thank you for your assistance. By: /s/ Evan R. Brovenick --------------------- Evan R. Brovenick President, Chief Executive Officer and Chairman of the Board