Request
for Withdrawal of Registration Statement on Form
S-1,
File
Number 333-145086 (the “Registration Statement”)
Dear
Mr.
Anderegg:
Accoona
Corp. (the ”Company”) hereby makes application to withdraw the Registration
Statement pursuant to Rule 477 under the Securities Act of 1933, as amended.
The
Company requests the withdrawal of the Registration Statement because it has
determined to not proceed with the registration and sale of securities covered
by the Registration Statement due to unfavorable market conditions. No
securities have been sold under the Registration Statement and all activity
in
pursuit of the public offering has been discontinued.
Accordingly,
the Company requests an order granting the withdrawal of the Registration
Statement be issued by the Securities and Exchange Commission as soon as
possible. Please provide a copy of the order granting withdrawal via facsimile
to the Company’s counsel, Andrew M. Ross, at (212) 504-3264. Should you have any
questions regarding this matter, please contact Mr. Ross at (212) 407-4838.
