rw_halberd.htm
Halberd
Corporation
10755
Vernon Avenue
Huntington
Woods, MI 48070
August
21, 2009
VIA EDGAR
TRANSMISSION
Securities
and Exchange Commission
100 F
Street, N.E.
Washington,
D.C. 20549
Attention:
Mark P. Shuman
Re:
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Halberd
Corporation
Registration
Statement on Form S-1
Filed
July 8, 2009
File
No. 333-160467
Request
for Withdrawal
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Dear Mr.
Shuman:
Pursuant
to Rule 477 promulgated under the Securities Act of 1933, as amended, (the
“Securities Act”), Halberd Corporation (the “Company”) hereby requests that the
Securities and Exchange Commission consent to the withdrawal of its Registration
Statement on Form S-1 (File No. 333-160467), together with all exhibits
thereto. The Company has determined not to proceed with the
registration and sale of its common stock at this time and to refocus its
corporate strategy on other aspects of its business. No shares of the
Company’s common stock have been sold pursuant to the Registration
Statement. The Company may undertake a subsequent private offering of
securities in reliance on Rule 155(c) of the Securities Act.
Accordingly,
the Company respectfully request that the Commission grant an order for the
withdrawal of the Registration Statement and declare the withdrawal effective as
soon as possible.
Should
you have any comments please contact the Company’s legal counsel, Gregg E.
Jaclin, at (732) 409-1212.
Very
truly yours,
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By:
/s/ Mark S.
Lundquist
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Mark S. Lundquist, CEO
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