Giant Motorsports, Inc.
13134 State Route 62
Salem, Ohio 44460
January 11, 2006
United States Securities and Exchange Commission
100 F Street N.E.
Washington, DC 20549-3561
Re: Giant Motorsports, Inc. - Registration Statement on Form SB-2
(File No. 333-129216) - Application for Withdrawal of Registration
Statement
Gentlemen:
Please be advised that Giant Motorsports, Inc. (the "Company") hereby
requests the withdrawal of its Registration Statement on Form SB-2 (File No.
333-129216) filed with the Commission on October 24, 2005 (the "Registration
Statement").
The Company requests the withdrawal of the Registration Statement in
response to the Staff's comment letter, dated November 23, 2005, in which the
Staff expressed its belief that the Company is not eligible to file a
Registration Statement on Form SB-2, but that the proper filing is on Form S-1.
While the Company has not concluded that it was ineligible to file its
Registration Statement on Form SB-2, it has elected to file a new Registration
Statement on Form S-1 to replace the Registration Statement on Form SB-2, which
it is requesting to be withdrawn hereby.
Please be advised that no sales of securities offered in the prospectus
forming a part of the Registration Statement were made.
Please accept this application for withdrawal upon receipt.
Very truly yours,
/s/ Russell A. Haehn
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Russell A. Haehn
Chairman and Chief Executive Officer
/s/ Gregory A. Haehn
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Gregory A. Haehn
President and Chief Operating Officer