CIRTRAN
CORPORATION
4125
South 6000 West
West
Valley City, Utah 84128
October
12, 2005
SECURITIES
AND EXCHANGE COMMISSION
Division
of Corporation Finance
Washington,
D.C. 20549
|
Attention:
|
David Ritenour
|
| |
Re:
|
CirTran
Corporation (the "Registrant")
|
Registration
Statement on Form SB-2
File
No.
333-117466
Filed
July 19, 2004
Dear
Messrs. Ritenour and Jones:
The
Registrant hereby applies to withdraw the above-referenced Registration
Statement, which was filed in July 2004 in connection with a standby equity
financing transaction. In May 2005, the Registrant terminated the standby
equity
facility (the “Standby Facility”). No funds were drawn on the Standby Facility
and no shares of stock were issued to the provider of the Standby Facility.
No
shares of stock were sold under this Registration Statement. The Registration
Statement was not declared effective by the SEC.
The
Registrant notes that it received a comment letter from the Staff dated
September 23, 2004 (the “2004 Comment Letter”). Additionally, the Registrant
notes that it has filed a subsequent registration statement on Form SB-2,
SEC
File No. 333-128549 (the “2005 Registration Statement”), and that the Registrant
received a comment letter in connection with the 2005 Registration Statement
dated September 30, 2005 (the “2005 Comment Letter”). The Company intends to
respond to the 2005 Comment Letter and include its responses to the comments
of
the Staff in the 2004 Comment Letter.
Sincerely,
CIRTRAN
CORPORATION
/s/
Iehab
Hawatmeh
By:
Iehab
Hawatmeh
President
and
Chief
Financial Officer