-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, NIwXQ1rbbDtkDlzXSB0m1la2pL6jrsMMk1WDg3ffcv1nbLOnUk03CTw7P8DFGpyI mundTfD/ax/3V1h2FNao/w== 0001047469-03-041863.txt : 20031223 0001047469-03-041863.hdr.sgml : 20031223 20031223172908 ACCESSION NUMBER: 0001047469-03-041863 CONFORMED SUBMISSION TYPE: RW PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20031223 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ACCPAC INTERNATIONAL INC CENTRAL INDEX KEY: 0001063239 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-PREPACKAGED SOFTWARE [7372] IRS NUMBER: 770469911 STATE OF INCORPORATION: DE FISCAL YEAR END: 0331 FILING VALUES: FORM TYPE: RW SEC ACT: SEC FILE NUMBER: 333-101976 FILM NUMBER: 031072080 BUSINESS ADDRESS: STREET 1: 2525 AUGUSTINE DRIVE CITY: SANTA CLARA STATE: CA ZIP: 95054 BUSINESS PHONE: 4085628800 MAIL ADDRESS: STREET 1: 2525 AUGUSTINE DRIVE CITY: SANTA CLARA STATE: CA ZIP: 95054 RW 1 a2125631zrw.htm RW

December 23, 2003

VIA EDGAR TRANSMISSION

Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.—Mailstop 4-6
Washington, D.C. 20549

RE:: ACCPAC INTERNATIONAL, INC.
REGISTRATION STATEMENT ON FORM S-1
(FILE NO. 333-101976)

Ladies and Gentlemen:

Pursuant to Rule 477 of the Securities Act of 1933, as amended, ACCPAC International, Inc. ("ACCPAC") hereby applies for an order granting the immediate withdrawal of its Registration Statement on Form S-1, together with all exhibits thereto, Commission File No. 333-101976 (the "Registration Statement"). The Registration Statement was originally filed on December 18, 2002.

None of ACCPAC's securities have been sold under the Registration Statement, which has been dormant since February 21, 2003. ACCPAC has entered into an Agreement and Plan of Merger, dated as of December 23, 2003, pursuant to which it has agreed to be acquired by The Sage Group plc, and ACCPAC no longer intends to sell securities under the Registration Statement. ACCPAC hereby respectfully requests that an order granting the withdrawal of the Registration Statement be issued by the Securities and Exchange Commission as soon as possible.

If you have any questions regarding this letter, please contact Andrea Vachss of Covington & Burling at (415) 591-7069.

Sincerely,

ACCPAC International, Inc.

By:

/s/ DAVID HOOD

David Hood
Chief Executive Officer

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