July 8, 1998

Securities and Exchange Commission
Filing Desk
450 Fifth Street, N.W.
Washington, D.C.  20549

        Re:    NU SKIN ASIA PACIFIC, INC. (RENAMED NU SKIN ENTERPRISES, INC.)
               Registration Statement on Form S-1
               Commission File No. 333-28513

Dear Ms. Parratt and Mr. Link:

        Pursuant to Rule 477 of the General  Rules and  Regulations  promulgated
under  the  Securities  Act of 1933,  as  amended,  Nu Skin Asia  Pacific,  Inc.
(renamed Nu Skin Enterprises,  Inc.) (the "Company") hereby applies for an order
granting the  immediate  withdrawal of its  Registration  Statement on Form S-1,
together with all exhibits,  Commission  File No.  333-28513 (the  "Registration
Statement"). The Registration Statement was originally filed with the Securities
and Exchange Commission (the "Commission") on June 4, 1997.

        Pursuant to the Registration Statement, the Company proposed to register
certain  shares  of its  Class A Common  Stock,  $.001  par  value per share for
issuance to the public (the "Offering"). The Company, upon consultation with the
underwriters,  has decided  not to proceed  with the  Offering at this time.  No
securities have been sold under the  Registration  Statement and all activity in
pursuit of the Offering has been discontinued.

        The Company hereby requests that the Commission  issue an order granting
the aforementioned withdrawal of the Registration Statement effective as soon as
possible.

                                    Sincerely,

                                    NU SKIN ENTERPRISES, INC.

                                    By:    /s/ Steven J. Lund
                                           Steven J. Lund

                                    Its:   President and Chief Executive Officer