TROUTMAN SANDERS LLP

                                ATTORNEYS AT LAW
                         A LIMITED LIABILITY PARTNERSHIP

                              THE CHRYSLER BUILDING
                              405 LEXINGTON AVENUE
                            NEW YORK, NEW YORK 10174
                             www.troutmansanders.com
                             TELEPHONE: 212-704-6000
                             FACSIMILE: 212-704-6288

Uri Doron                                              Direct Dial: 212-704-6027
uri.doron@troutmansanders.com                          Fax:         212-704-6288

                                  June 17, 2005

Via EDGAR
- ---------
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0405
Attention: Russell Mancuso

                  Re:      Ophthalmic Imaging Systems
                           Amendment to Form SB-2 filed on June 9, 2005
                           File No. 333-116217

Dear Mr. Mancuso:

         On behalf of  Ophthalmic  Imaging  Systems (the  "Company"),  we hereby
request that the Company's Amendment to Form SB-2 (the "Amendment") be withdrawn
effective  today,  June 16, 2005. As a result of a clerical  error the Amendment
was filed  under File No.  333-116217  while the  Amendment  relates to the File
333-123892.  The  revised  pre-effective  Amendment  to  Form  SB-2  under  File
333-123892 is being filed concurrently herewith.

         Should  you  have  any  questions  or  require  additional  information
regarding the foregoing, please contact the undersigned at Tel: 212-704-6027.

                                             Sincerely,

                                             Uri Doron, Esq.



           ATLANTA o HONG KONG o LONDON o NEW YORK o NORFOLK o RALEIGH
          RICHMOND o TYSONS CORNER o VIRGINIA BEACH o WASHINGTON, D.C.