ASIA PROPERTIES, INC. 114 Magnolia Street Suite 400-115 Bellingham, MA 98225 (360) 992-2841 July 26, 2004 VIA ELECTRONIC SUBMISSION Securities and Exchange Commission 450 Fifth Street, N.W. Judiciary Plaza Washington, D.C. 20549 Re: Asia Properties, Inc. (the "Company") SEC File Number: 333-105921 Form SB-2 Registration Statement Ladies and Gentlemen: We previously filed the above-referenced Form SB-2 registration statement. We hereby request that such registration statement be withdrawn at your earliest convenience. No securities were offered or sold pursuant to this registration statement. We request this withdrawal because we have terminated our initial agreement with Cornell Capital Partners which formed the primary securities registered by the SB-2. We are in the final process of entering into new agreements with Cornell Capital Partners and will file a new SB-2 at that time with those documents. That filing will be accompanied by a response letter reflecting your comments to the most recent SB-2 filing made by Asia Properties, Inc. If you have any questions concerning this matter, please contact the undersigned or our securities counsel, M. Richard Cutler, Cutler Law Group, 3206 West Wimbledon Drive, Augusta, GA 30909; (706) 737-6600. Please note that all new correspondence should be sent to Mr. Cutler. Thank you for your assistance in this matter. ASIA PROPERTIES, INC. By: /s/ Daniel Mckinney Daniel Mckinney President