RW 1 t15035rw.txt WITHDRAWAL OF REGISTRATION STATEMENT HOLLINGER INC. 10 Toronto Street Toronto Ontario Canada, M5C 2B7 416.363.8721 December 20, 2004 Securities and Exchange Commission 450 Fifth Street Washington, D.C. 20549 Re: Hollinger Inc. Application for Withdrawal of Registration Statement on Form F-4 (File No. 333-106587) (the "Registration Statement") Ladies and Gentlemen: Hollinger Inc. ("Hollinger") hereby applies for withdrawal of the Registration Statement pursuant to Rule 477 under the Securities Act of 1933, as amended. As a result of current circumstances, Hollinger does not expect in the near term to be able to commence and complete the exchange offer contemplated by the Registration Statement. No securities were sold in connection with the Registration Statement. By execution of this letter below, Ravelston Management Inc. and 504468 N.B. Inc., the other two registrants under the Registration Statement, hereby join in this application for withdrawal of the Registration Statement. Please call John J. O'Brien (212-558-3944) or Sara A. Cohen (212-558-1625), of Sullivan & Cromwell LLP, if you have any questions relating to this application. Securities and Exchange Commission -2- Very truly yours, HOLLINGER INC. By: /s/ Peter G. White --------------------------------------- Name: Peter G. White Title: Vice President, Operations and Secretary RAVELSTON MANAGEMENT INC. By: /s/ Peter G. White --------------------------------------- Name: Peter G. White Title: Executive Vice President 504468 N.B. Inc. By: /s/ Peter G. White --------------------------------------- Name: Peter G. White Title: Executive Vice President cc: Katherine Hsu Max A. Webb (Division of Corporation Finance)