IT&E International Group 505 Lomas Santa Fe Drive, Suite 200 Solana Beach, California 92075 Phone: (858) 366-0970 March 17, 2005 VIA EDGAR Securities and Exchange Commission 450 Fifth Street, N.W. Judiciary Plaza Washington, D.C. 20549 RE: IT&E International Group Registration Statement on Form S-3 File Number: 333-120580 Ladies and Gentlemen: Pursuant to Rule 477 under the Securities Act of 1933, as amended (the ?Securities Act?), IT&E International Group (the ?Company?) hereby respectfully requests the withdrawal of its Registration Statement on Form S-3, together with all exhibits thereto (File No. 333-120580) (the ?Registration Statement?), effective immediately. The Registration Statement is being withdrawn as it has been deemed that the Company does not qualify to submit a Registration Statement on Form S-3, as our securities are not listed or registered on a national securities exchange or are quoted on the automated quotation system of a national securities association. The Company plans to revise our Registration Statement on the appropriate form. Furthermore, no securities have been sold regarding the Form S-3 Registration Statement offering. The Registration Statement has not been declared effective by the Commission. Accordingly, we respectfully request that the Commission grant an order for the withdrawal of the Registration Statement and declare the withdrawal effective as soon as possible. If you have any questions regarding this application, please contact the undersigned at (858) 366-0970. Very truly yours, IT&E International Group Peter R. Sollenne Chief Executive Officer