Michael L. Pflaum
(212) 801-6843

                                                    April 17, 2006

VIA FACSIMILE, FIRST CLASS MAIL AND EDGAR

U.S. Securities and Exchange Commission Division of Corporation Finance
Securities and Exchange Commission 100 F Street, N.E.
Washington, D.C.  20549
Mail Stop 6010

Attn:    Mr. Russell Mancuso
         Mr. Tom Jones

                  Re:    SmarTire Systems Inc. (the "Company")
                         Registration Statement on Form SB-2/A (No. 333-126386)

Ladies and Gentlemen:

            On   behalf   of  the   Company,   we   hereby   request   that  the
above-referenced   Registration   Statement  be  withdrawn  at  this  time.  The
Registration Statement was not previously declared effective by the staff of the
Commission and no securities were sold pursuant to such Registration  Statement.
The  Company's  decision  to withdraw  the  Registration  Statement  was made in
response to a telephone  call from Mr. Tom Jones of the  Securities and Exchange
Commission to Michael D. Helsel,  legal counsel to the Company  indicating  that
the SB-2/A had been filed under an incorrect filing number.  The Company will be
re-filing the SB-2/A with the correct filing number.

            In  accordance  with Rule 477 under the  Securities  Act of 1933, as
amended,  and  certain  telephone  interpretations  of the  staff,  the  Company
respectfully  requests  that the  registration  filing  fee  previously  paid in
connection  with the  Registration  Statement be carried  forward and taken into
account in any subsequent Securities Act filing.

            Please do not hesitate to contact me (tel:  212-801-6843) or Michael
D. Helsel of this office (tel: 212-801-6962) if you have any questions regarding
this letter.

                                          Very truly yours,


                                          /s/ Michael L. Pflaum

                                          Michael L. Pflaum