APOGENT TECHNOLOGIES INC.
                    c/o Fisher Scientific International Inc.
                                One Liberty Lane
                          Hampton, New Hampshire 03842

August 20, 2004

Securities and Exchange Commission
450 Fifth Street, N.W.
Judiciary Plaza
Washington, DC  20549

Re:  Apogent Technologies Inc.;
     Registration Statement on Form S-3 (Registration No. 333-112468)

Ladies and Gentlemen:

     In accordance with Rule 477 promulgated under the Securities Act of 1933,
as amended, Apogent Technologies Inc. (the "Company") and each of the
subsidiaries of the Company (the "Guarantor Subsidiaries") that guaranteed the
debt securities which are the subject of the Registration Statement on Form S-3
(Registration No. 333-112468) (the "Registration Statement") filed with the
Securities and Exchange Commission on February 4, 2004, hereby withdraw such
Registration Statement. The Company and the Guarantor Subsidiaries are
withdrawing the Registration Statement because the Company does not intend to
register the Floating Rate Senior Convertible Contingent Debt Securities due
2033 (the "CODES") or the shares of common stock of the Company into which the
CODES were convertible at the time of the filing of the Registration Statement
(the "Conversion Shares") for resale by the holders of such securities as
contemplated in the Registration Statement. Pursuant to an offer to exchange the
CODES for newly-issued senior convertible contingent debentures of the Company
and a concurrent consent solicitation to terminate the Resale Registration
Rights Agreement, dated December 17, 2003, relating to the CODES and the
Conversion Shares, the Company and the Guarantor Subsidiaries are no longer
obligated to register the CODES or the Conversion Shares as of the consummation
of the exchange offer and termination of such Registration Rights Agreement on
August 3, 2004. No CODES or Conversion Shares have been sold under the
Registration Statement.




     If you have any questions with respect to this letter, please call either
Yasmeena F. Chaudry of the law firm of Skadden, Arps, Slate, Meagher & Flom
LLP at (212) 735-2683 or the undersigned at (603) 334-1700. We request that we
be notified of the consent of the Securities and Exchange Commission to the
withdrawal of the Registration Statement by a telephone call to the undersigned
at (603) 334-1700.

                                            Sincerely,

                                            Apogent Technologies Inc.

                                            By:  /s/ Michael K. Bresson
                                               -----------------------------
                                               Name:  Michael K. Bresson
                                               Title: Executive Vice President -
                                                      Administration, General
                                                      Counsel and Secretary