Time America, Inc.
8840 East Chaparral Road, Suite 100
Scottsdale, Arizona 85250
December 9, 2005
U.S. Securities & Exchange Commission
100 F Street NE
Washington, D.C. 20549
Attn: Maryse Mills-Apenteng
Re: Time America, Inc. (the “Company”)
Registration Statement on Form S-2 (File No. 333-126830)
Filed on July 22, 2005, as amended
Application for Withdrawal of Registration Statement
Ladies and Gentlemen:
Pursuant to Rule 477 of the Securities Act of 1933, as amended, we hereby request that the Securities and Exchange Commission withdraw the Company’s Registration Statement on Form S-2, as amended (File No. 333-126830) (the “Registration Statement”). In light of the Commission’s comments to the Company’s previously filed Registration Statement, the Company has elected to withdraw the Registration Statement. No securities were sold under the Registration Statement.
Should you have any questions concerning the foregoing, please contact me or Gregory R. Hall of Squire, Sanders & Dempsey L.L.P., the Company’s legal counsel. Our telephone numbers are (480) 296-0442 and (602) 528-4134, respectively.
| Very truly yours, | |
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| /s/ CRAIG J. SMITH |
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| Craig J. Smith | |
| Chief Financial Officer |