PARADIGM MEDICAL INDUSTRIES, INC.
                              2355 South 1070 West
                           Salt Lake City, Utah 84119
                            Telephone: (801) 977-8970
                            Facsimile: (801) 977-8973





                                  July 25, 2006




Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549

         Re:      Paradigm Medical Industries, Inc.
                  Application for Withdrawal of Registration Statement on
                  Form SB-2 and Amendment No. 1 to Registration Statement on
                  Form SB-2
                  Commission File No. 333-135034

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 Registrant's Registration Statement No. 333-135034,
on Form SB-2,  together  with any  exhibits  filed  thereto  (the  "Registration
Statement"), which was filed with the Commission on June 15, 2005, and Amendment
No. 1 to the Registration Statement, which was filed with the Commission on July
13, 2006.

         Under the terms of the  callable  secured  convertible  notes that were
sold in connection  with the securities  purchase  agreement that the Registrant
entered into on February 28, 2006 with four accredited investors, the Registrant
was required to file the Registration  Statement with the Commission to register
for resale the shares of common stock  issuable upon  conversion of the callable
secured  convertible  notes and exercise of the warrants based on the conversion
price of the notes and the exercise price of the warrants in effect from time to
time.  The  Registrant  filed the  Registration  Statement  on June 15,  2006 to
register the common shares issuable upon conversion of the notes and exercise of
the warrants.  An amendment to the Registration  Statement was filed on July 13,
2006.

         The Registrant  requests the Commission's  consent to the withdrawal of
the Registration  Statement and Amendment No. 1 to the  Registration  Statement.
The  Registrant   intends  to  file  another   registration   statement  if  the
shareholders vote at the Registrant's Annual Shareholders Meeting to approve the
proposed amendment to the Registrant's  Certificate of Incorporation to increase
the  number of  authorized  shares of common  stock from  250,000,000  shares to
800,000,000 shares.

         Because the filing of the Registration  Statement  constitutes an offer
to the public,  the Commission staff has concerns with regards to the Registrant
including shares in the Registration  Statement that it is not yet authorized to
issue until such time as the shareholders  approve the proposed amendment to the
Certificate  of  Incorporation  to  increase  the  authorized  common  shares to
800,000,000 shares. This will confirm that no securities of Registrant have been
sold in  connection  with the  Registration  Statement or Amendment No. 1 to the
Registration Statement.



July 25, 2006
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/ Raymond P.L. Cannefax
                                              -------------------------
                                                 Raymond P.L. Cannefax
                                                 President and Chief Executive
                                                  Officer