March 9,
2009
Via
EDGAR
Securities
and Exchange Commission
Division
of Corporation Finance
100 F
Street, N.E.
Washington,
D.C. 20549
Registration
Statement on Form S-1
File No.
333-145801
Request for Withdrawal of
Registration Statement
Ladies
and Gentlemen:
Pursuant
to Rule 477 promulgated under the Securities Act of 1933, as amended (the
“Act”), Positron Corporation (the “Registrant”) hereby respectfully requests
that the Securities and Exchange Commission (the “Commission”) consent to the
withdrawal of the Registrant’s registration statement on Form S-1 (File Number
File No. 333-145801) (the “Registration Statement”), which the Registrant filed
with the Commission on August 30, 2007. The Registrant hereby
confirms that no securities have been sold pursuant to the Registration
Statement.
The Registrant hereby respectfully
requests that the Commission issue a written order granting the withdrawal of
the Registration Statement as soon as possible. Please fax a copy of the written
order to the attention of the undersigned and to the attention of Peter
Campitiello, Esq. at (212) 216-8001.
The
registrant further requests that, in accordance with Rule 457(p) under the Act,
all fees paid to the Commission with the filing of the Registration Statement be
credited for future use.
If you
have any questions regarding this request, please call Peter Campitiello, Esq.,
at (212) 216-8085.
Very
truly yours,
/s/
Patrick Rooney
Patrick
Rooney,
Chairman
7715
Loma Court, Suite A, Fishers, IN 46038