Bioenvision, Inc.
                          509 Madison Avenue, Suite 404
                            New York, New York 10022


June 3, 2004

VIA EDGAR
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

Re:   Bioenvision, Inc..
      Request to Withdraw Post-Effective Amendment to Registration
      Statement on Form S-3  (File No. 333-97443)

Ladies and Gentlemen:


Pursuant to Rule 477 of the Securities Act of 1933, as amended (the "Securities
Act"), Bioenvision, Inc. a Delaware corporation (the "Registrant"), respectfully
makes application to the Securities and Exchange Commission (the "Commission")
to withdraw the Post-Effective Amendment to Registration Statement on Form S-3,
together with all exhibits (the "Post-Effective Amendment") (File No.
333-97443). The Post-Effective Amendment has not been declared effective by the
Staff.

We are requesting the withdrawal of the Post-Effective Amendment per the
suggestion of the Commission. No securities were sold in connection with the
Post-Effective Amendment. The Post Effective Amendment was converted into a
Registration Statement on Form SB-2 (File No. 333-115816), which was filed with
the Commission on May 24, 2004.

Please direct any questions you have regarding Registrant's request to withdraw
the Post-Effective Amendment to David Luci at (212) 750-6660 or to Kristen
Dunker, counsel of the Registrant, at (212) 318-6467 or via email at
kristendunker@paulhastings.com.


Sincerely,


/s/ David P. Luci


David P. Luci
Director of Finance and General Counsel
Bioenvision, Inc.