Five Nines Ltd
                                                          106-1641 Lonsdale Ave.
                                                   North Vancouver, B.C. V7M 2J5
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Phone (604) 880-3144
Fax (604) 929-8734





                                                                  March 16, 2004

VIA EDGAR

U. S. Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N,W.
Washington, D.C. 20545


                               Re: Five Nines Ltd.
                             Withdrawal of Form SB-2
                               File No. 333-110385


Gentlemen and Ladies;


Pursuant to Rule 477(a) of the  Securities  Act of 1933, as amended,  Five Nines
Ltd, (the "Company") hereby requests that the Securities and Exchange Commission
(the  "Commission")  consent to the withdrawal of its Registration  Statement on
Form  SB-2  tiled  with the  Commission  on  November  12,  2003  (SEC  File No.
333-110385)   along  with  any  exhibits   filed   thereto  (the   "Registration
Statement").

Such  withdrawal is requested as Five Nines Ltd. does not have the funds to  pay
the legal and accounting fees necessary to proceed with this filing.

Furthermore,  no securities have been sold regarding the Form SB-2  Registration
Statement offering.  The Registration  Statement has not been declared effective
by the Commission.

Five Nines Ltd. plans to rely on Rule 155(c) for subsequent private offerings of
its securities  and  utilize  the  "Safe Harbor" from  integration  provided  by
Rule 155.

Accordingly,  we respectfully request that the Commission grant an order for the
withdrawal of the Registration Statement and declare the withdrawal effective as
soon as possible.

If you have  any  questions  regarding  this  application,  please  contact  the
undersigned at the above listed telephone number.


Very truly yours,



Five Nines Ltd.

By: /s/ Carman Parente
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Carman Parente, President