MEDIZONE INTERNATIONAL, INC. 

350 East Michigan Avenue, Suite 500
Kalamazoo, Michigan  49007

April 25, 2018 

VIA E-MAIL AND EDGAR SUBMISSION

Securities and Exchange Commission

Attention: John Reynolds

Division of Corporate Finance 

Mail Stop 3561

100 F Street N.W. 

Washington, D.C. 20549 

Re:            Medizone International, Inc.

Withdrawal of Registration Statement on Form S-1, File No. 333-224119

Ladies and Gentlemen: 

Pursuant to Rule 477 promulgated under the Securities Act of 1933, as amended (the “ Securities Act ”), Medizone International, Inc. (the “ Company ”) hereby respectfully requests that the Securities and Exchange Commission (the “ Commission ”) consent to the withdrawal of its Registration Statement on Form S-1, File No. 333-224119 (as amended, together with all exhibits thereto, the “ Registration Statement ”), effective as of the date hereof or at the earliest practicable date hereafter. The Registration Statement was filed by the Company on April 3, 2018; Amendment No. 1 was filed by the Company on April 13, 2018.

The Registration Statement has not been declared effective by the Commission, and no securities have been issued or sold under the Registration Statement.

The Company requests that, in accordance with Rule 457(p) under the Securities Act, all fees paid to the Commission in connection with the filing of the Registration Statement be credited for future use.

If you have any questions with respect to this matter, please contact the Company’s counsel, Kevin Pinegar of Durham Jones & Pinegar, P.C., at (801) 415-3000. 

 

cc:            Pamela Howell

Jonathan Burr