[Paradigm Medical Industries, Inc. Letterhead]
June 24, 2005
VIA FACSIMILE
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Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W., Mail Stop 0306
Judiciary Plaza
Washington, D.C. 20549
Attn: Thomas A. Jones, Esq.
Senior Attorney
Re: Paradigm Medical Industries, Inc.
Application for Withdrawal of Post-Effective Amendment No. 2 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, the Securities and Exchange Commission (the "Commission")
consent to the withdrawal of the Registrant's Post-Effective Amendment No. 2 to
the Registration Statement No. 333-1030651, which was previously filed with the
Commission on February 3, 2005, on Form SB-2, together with any exhibits filed
thereto.
The Amendment No. 2 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 February 3,
2005, Registrant filed Post-Effective Amendment No. 3 to the Registration
Statement on Form SB-2 on June 24, 2005.
Because Post-Effective Amendment No. 2 to the Registration Statement is
no longer current, and has been superceded by Post-Effective Amendment No. 3,
Registrant requests for the withdrawal of Post-Effective Amendment No. 2. No
securities of Registrant have been sold in connection with the filing of
Post-Effective Amendment No. 2 to the Registration Statement.
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
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John Y. Yoon
President and Chief Executive Officer