July 11, 2005
VIA FACSIMILE (202) 772-9218
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Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549
Attn: Donald Hunt
Re: Paradigm Medical Industries, Inc.
Withdrawal of Application for Withdrawal of Registration
Statement on Form SB-2
Commission File No. 333-106842
Ladies and Gentlemen:
Paradigm Medical Industries, Inc., a Delaware corporation (the
"Registrant"), hereby requests the Securities and Exchange Commission (the
"Commission") to consent to the withdrawal of the Application for Withdrawal of
the Registrant's Registration Statement No. 333-106842, on Form SB-2 (the
"Registration Statement"), which was filed with the Commission on June 30, 2005.
The Registration Statement was filed (i) to register for sale shares of
Registrant's common stock and (ii) to register for resale shares of Registrant's
common stock for certain shareholders, optionholders and warrantholders. The
Registration was filed with the Commission on February 3, 2005 and declared
effective on February 10, 2005. In order to reflect and disclose material
changes in Company's operations since February 3, 2005, Registrant filed
Post-Effective Amendment No. 1 to the Registration Statement on Form SB-2 on
June 29, 2005.
Registrant incorrectly filed an Application for Withdrawal of the
Registration Statement filed on February 3, 2005. To remedy this incorrect
filing, Registrant requests withdrawal of the Application for Withdrawal of
Registration Statement on Form SB-2, Commission File No. 333-106842, which was
filed on June 30, 2005.
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