APEX WEALTH ENTERPRISES LIMITED Unit 1502, 15th Floor Worldwide House 19 Des Voeux Road Central, Hong Kong October 28, 2003 Michael Ferraro Attorney-Advisor Securities and Exchange Commission Mail Stop 0304 450 Fifth Street, N.W. Washington, D.C. 20549 USA Dear Mr. Ferraro: RE: Apex Wealth Enterprises Limited Registration Statement on Form F-1: File No. 333-108930 Apex Wealth Enterprises Limited (the "Company") hereby notifies the Securities and Exchange Commission of its decision to withdraw the above-referenced Form F-1 Registration Statement and requests that an order consenting to the withdrawal be entered effective immediately. The Company filed the Registration Statement on Form F-1 with respect to shares of its Common Stock on September 18, 2003. Due to changes in market conditions, it has decided not to proceed with a blank check offering at this time. Accordingly, no shares of Common Stock have been or will be sold pursuant to the filed Registration Statement. If you have any questions, please contact Simon Luk of Heller Ehrman White & McAuliffe at 001-852-2292-2000. Very truly yours, Apex Wealth Enterprises Limited By: /s/ LI SZE TANG ______________________ Name: Li Sze Tang Title: Chief Executive Officer and Chairman of the Board