Unassociated Document
HLS
Systems International, Ltd.
625
Broadway, Suite 1111
San
Diego, CA 92101
February
14, 2007
VIA
FACSIMILE AND EDGAR
Securities
and Exchange Commission
Division
of Corporation Finance
100
F
Street, N.E.
Washington,
D.C. 20549-7010
Facsimile: 202-772-9220
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Re:
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Registration
Statement on Form S-4 (File No. 333-140700) of HLS Systems International,
Ltd.
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Ladies
and Gentlemen:
Pursuant
to Rule 477 promulgated under the Securities Act of 1933, as amended, HLS
Systems International, Ltd. (the “Registrant”) hereby applies for the immediate
withdrawal of its Registration Statement on Form S-4, together with all exhibits
thereto, File No. 333-140700 (collectively, the “Registration Statement”). The
Registration Statement was filed with the Securities and Exchange Commission
on
February 14, 2007 on Form S-4 in error and should have been filed on Form S-4/A.
As a result, the Registrant is withdrawing the Registration Statement and will
immediately re-file the Registration Statement on Form S-4/A. The Registration
Statement has not been declared effective and no securities have been sold
pursuant to the Registration Statement.
If
you
have any questions regarding this application for withdrawal, please contact
the
undersigned or Douglas J. Rein of DLA Piper US LLP, at
858-677-1443.
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Sincerely, |
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/s/ Kerry Propper |
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Kerry Propper |
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Chief Financial Officer |
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HLS
Systems International, Ltd.
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