August 7, 1998 Securities and Exchange Commission Washington, DC 20549 Re: SGI International Registration Statement on Form S-2 Commission File No. 333-44789 Ladies and Gentlemen: On behalf of the Registrant ("SGI"), we respectfully request to withdraw Post-Effective Amendment No. 1 to the Registration Statement on Form S-2 filed on January 23, 1998, and amended on April 20, 1998, May 14, 1998, June 15, 1998, July 1, 1998, and July 29, 1998. The Registrant intends to file a new Registration Statement covering the same securities. Please contact me with any comments, questions or concerns. Very truly yours, /s/ DAVID A. FISHER David A. Fisher