PARADIGM MEDICAL INDUSTRIES, INC.
2355 South 1070 West
Salt Lake City, Utah 84119
(801) 977-8970
January 6, 2005
VIA EDGAR
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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 Registration Statement on Form S-3
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 Amendment No. 1 to the
Registration Statement No. 333-103061, which was previously filed with the
Commission on April 22, 2004, on Form S-3, together with any exhibits filed
thereto (the "Amendment").
The Amendment 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. The Registrant
has determined that a post-effective amendment on Form SB-2 should be used to
amend the Form S-3 because Registrant does not meet the requirements for
utilizing a Form S-3. For this reason, Registrant requests for the withdrawal of
the Amendment.
No securities of Registrant have been sold in connection with the
filing of the Amendment. Registrant intends to amend the Registration Statement
by filing a post-effective amendment on Form SB-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
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John Y. Yoon
President and Chief Executive Officer