PARADIGM MEDICAL INDUSTRIES, INC.
                              2355 South 1070 West
                           Salt Lake City, Utah 84119
                                 (801) 977-8970




                                                 February 8, 2005




VIA EDGAR
---------

Securities and Exchange Commission
450 Fifth Street, N.W.
Judicial Plaza
Washington, D.C. 20549

Attn:    Thomas A. Jones
         Senior Attorney

         Re:      Paradigm Medical Industries, Inc.
                  Application for Withdrawal of Post-Effective Amendment No. 1 
                  to Registration Statement on Form SB-2
                  Commission File No. 333-103061

Ladies and Gentlemen:

         Paradigm  Medical  Industries,   Inc.,  a  Delaware   corporation  (the
"Registrant"),  hereby requests pursuant to Rule 477(a) of the Securities Act of
1933, as amended, that the Securities and Exchange Commission (the "Commission")
consent to the withdrawal of the Registrant's  Post-Effective Amendment No. 1 to
the Registration  Statement No. 333-103061,  which was previously filed with the
Commission on January 11, 2005, on Form SB-2,  together with any exhibits  filed
thereto.

         The  Amendment  No. 1 was filed as a  post-effective  amendment  to the
Registration  Statement to register  for resale  shares of  Registrant's  common
stock for certain  shareholders,  optionholders and warrantholders.  In order to
reflect and disclose material changes in Company's  operations since January 11,
2005,  Registrant  filed  Post-Effective  Amendment  No.  2 to the  Registration
Statement on Form SB-2 on February 3, 2005.

         Because Post-Effective Amendment No. 1 to the Registration Statement is
no longer current,  and has been superceded by  Post-Effective  Amendment No. 2,
Registrant  requests for the  withdrawal of  Post-Effective  Amendment No. 1. No
securities  of  Registrant  have  been  sold in  connection  with the  filing of
Post-Effective Amendment No. 1 to the Registration Statement.





February 8, 2005
Page 2
---------------------------

         Please  direct any questions or comments  regarding  this filing to the
undersigned at (801) 977-8970 or Randall A. Mackey, Esq. at (801) 575-5000.

                                    PARADIGM MEDICAL INDUSTRIES, INC.



                                    By:   /s/ John Y. Yoon           
                                        ----------------------------------------
                                           John Y. Yoon
                                           President and Chief Executive Officer