[LETTERHEAD OF WIRELESS, INC.] October 4, 2000 VIA EDGARLINK AND OVERNIGHT MAIL Barry Summer, Esq. Kathleen Krebs, Esq. Candace Cavalier, Esq. Mr. Terry French Securities and Exchange Commission Division of Corporate Finance 450 Fifth Street, N.W. Judiciary Plaza Washington, D.C. 20549 Re: Wireless, Inc. (File No. 333-35304) APPLICATION FOR WITHDRAWAL OF REGISTRATION STATEMENT ON FORM S-1 ----------------------------------------------------------------- Ladies and Gentlemen: Pursuant to Rule 477(a) promulgated under the Securities Act of 1933, as amended, Wireless, Inc. (the "Registrant") hereby applies for an order, effective October 4, 2000 or soon as possible thereafter, granting the withdrawal of its Registration Statement on Form S-1, File Number 333-35304, together with all amendments and exhibits thereto (collectively, the "Registration Statement"). The Registration Statement was originally filed with the Securities and Exchange Commission (the "Commission") on April 20, 2000. The Registrant believes that due to unfavorable market conditions, the terms that could be obtained in the current public marketplace are not sufficiently attractive to warrant proceeding with the offering at this time. The Registration Statement was not declared effective by the Commission and no securities have been or will be offered or sold under the Registration Statement. Accordingly, the Registrant hereby requests an order granting the withdrawal of the Registration Statement be issued by the Commission effective October 4, 2000 or as soon as possible thereafter. Please provide our attorneys with a facsimile copy of the order consenting to the withdrawal of the Registration Statement as soon as it is available. Their facsimile number is (650) 496-2885. BARRY SUMMER, ESQ., ET AL SECURITIES AND EXCHANGE COMMISSION OCTOBER 4, 2000 PAGE 2 Should you have any questions regarding this matter, please contact Jonathan Shapiro, Esq. of Brobeck, Phleger & Harrison LLP, legal counsel to the Registrant, at (650) 812-2212. Very truly yours, Wireless, Inc. By: /s/ Antonio Canova --------------------------------------- Antonio Canova EXECUTIVE VICE PRESIDENT AND CHIEF FINANCIAL OFFICER cc: The Nasdaq Stock Market, Inc.