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Imaging Systems (the "Company"), we hereby request that the Company's Amendment to Form SB-2 (the "Amendment") be withdrawn effective today, June 16, 2005.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.