Strategy International Insurance Group, Inc. Letterhead

                                 January 6, 2005

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,


                                    Strategy International Insurance Group, Inc.


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