[Globix Letterhead]
December 6, 2004
VIA EDGAR AND COURIER
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Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street NW
Washington, D.C. 20549
Attention: Barbara C. Jacobs
Re: GLOBIX CORPORATION WITHDRAWAL OF CO-REGISTRANTS
ON REGISTRATION STATEMENT (FILE NO.333-97067)
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Dear Ms. Jacobs:
Reference is made to (1) the Registration Statement on Form S-1 (File
No. 333-97067) (the "REGISTRATION STATEMENT") initially filed with the
Securities and Exchange Commission (the "COMMISSION") on July 25, 2002 by Globix
Corporation, a Delaware corporation (the "COMPANY") which was not declared
effective, and (2) the letter from the Company to the Commission dated March 15,
2004 (the "WITHDRAWAL REQUEST"), whereby, pursuant to Rule 477(a) and (b) of the
Securities Act of 1933, as amended (the "SECURITIES ACT"), the Company requested
that the Commission withdraw the Registration Statement effective as of the date
thereof or as soon thereafter as practicable.
In addition to the Company, the following subsidiaries of the Company
were listed as co-registrants on the Registration Statement: Comstar Telecom &
Wireless, Inc., a Georgia corporation (333-97067-01), Comstar.Net, Inc., a
Georgia corporation (333-97067-02), GRE Consulting, Inc., a New York corporation
(333-97067-06), PFM Communications, Inc., a New York corporation (333-97067-07),
NAFT International Ltd., a New York corporation (333-97067-008), NAFT Computer
Service Corporation, a New York corporation (333-97067-09), Gamenet Corporation,
a New York corporation (333-97067-10), Bluestreak Digital, Inc., a New York
corporation (333-97067-11), 415 Greenwich GC MM, LLC, a New York corporation
(333-97067-03), 415 Greenwich GC Tenant, LLC, a New York corporation
(333-97067-04) and 415 Greenwich GC, LLC, a New York corporation (333-97067-05).
All of the subsidiaries of the Company listed above have been dissolved except
for the 415 Greenwich GC entities.
Securities and Exchange Commission
December 6, 2004
Page 2
The undersigned along with the Company acting on behalf of those
entities that were dissolved, hereby join in the Company's Withdrawal Request.
Please call Bonnie J. Roe of Day Berry & Howard LLP at (203) 977-7381 with any
questions you may have.
Very truly yours,
415 GREENWICH GC, LLC
By: /s/ James C. Schroeder
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James C. Schroeder, Secretary
415 GREENWICH GC TENANT, LLC
By: /s/ James C. Schroeder
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James C. Schroeder, Secretary
415 GREENWICH GC MM, LLC
By: /s/ James C. Schroeder
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James C. Schroeder, Secretary
GLOBIX CORPORATION
on behalf of Bluestreak Digital, Inc,
Gamenet Corporation, NAFT Computer Service
Corporation, NAFT International Ltd., PFM
Communications, Inc., GRE Consulting, Inc.,
Comstar.Net, Inc., Comstar Telecom &
Wireless, Inc.
By: /s/ James C. Schroeder
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James C. Schroeder
Vice President & General Counsel
cc: Bonnie J. Roe, Esq.
Day, Berry & Howard LLP