[Strategy International Insurance Group, Inc. Letterhead]

                                December 30, 2004



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

                  Re:  Registration Statement No. 333-121734 on Form S-8

Gentlemen:

            Pursuant  to Rule 477(a)  promulgated  under the  Securities  Act of
1933,  Strategy  International  Insurance  Group,  Inc. (the  "Company")  hereby
applies for the withdrawal of the above-captioned Registration Statement and all
amendments  and exhibits  thereto as the Company has  determined  not to proceed
with the  offering  of the  Common  Stock  contemplated  to be  offered  by said
Registration  Statement.  No  sales  have  been  made  under  said  Registration
Statement.


                                Very truly yours,

                                /s/ Strategy International Insurance Group, Inc.
                                Strategy International Insurance Group, Inc.


                                    By: /s/ Ed Kruk
                                        ----------------------------------------
                                    Name:  Ed Kruk
                                    Title: Chief Financial Officer