PARADIGM MEDICAL INDUSTRIES, INC.
                              2355 South 1070 West
                           Salt Lake City, Utah 84119







                                                   June 2, 2003



VIA EDGAR

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

Attn: Peggy A. Fisher,
      Assistant Director

         Re:  Paradigm Medical Industries, Inc.
              Application for Withdrawal of Registration Statement on Form S-3
              Commission File No. 333-105115

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  registration  statement  No.
333-105115,  which was  previously  filed with the Commission on May 9, 2003, on
Form  S-3,   along  with  any  exhibits  and   amendments   filed  thereto  (the
"Registration Statement").

         The  Registration  Statement was filed to register for resale shares of
Registrant's common stock that the Registrant may issue through a private equity
line of credit  agreement.  The Registrant has determined  that it is not in the
best interests of its  shareholders at this time to obtain  financing  through a
private equity line of credit. For this reason, Registrant requests a withdrawal
of the Registration Statement.

         No  securities  of  Registrant  have been sold in  connection  with the
Registration  Statement.  The  Registration  Statement  has  not  been  declared
effective by the Commission.





         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.

                                           Very truly yours,

                                           Paradigm Medical Industries, Inc.

                                           /s/ Jeffrey F. Poore
                                           -------------------------------------
                                           Jeffrey F. Poore
                                           President and Chief Executive Officer