February 10, 2003

Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549

Re:      SVI Solutions, Inc.
         Request to Withdraw Registration Statement on Form S-3
          Filed on January 23, 2001
         SEC File Number 333-54168

Ladies and Gentlemen,

Pursuant to Rule 477 of the Securities Act of 1933, as amended, (the "Act") SVI
Solutions, Inc. (the "Company") hereby requests that the Securities and Exchange
Commission (the "Commission") consent to the withdrawal of the Company's
Registration Statement on Form S-3 which was filed with the Commission on
January 23, 2001 (File Number 333-54168), along with any exhibits, (the
"Registration Statement").

The Company requests that such consent be granted on grounds that the Company is
not currently eligible to use Form S-3 for the purpose of registering the sale
of shares in a secondary offering and that the Company intends to file a Form
S-1 to supersede the Registration Statement.

The Company confirms that the Registration Statement has not been declared
effective, no securities have been sold pursuant to the Registration Statement
or the prospectus contained therein, and no preliminary prospectus contained in
the Registration Statement has been distributed.

Pursuant to the foregoing, the Company hereby respectfully requests that a
written order granting the withdrawal of the Registration Statement be issued by
the Commission.

It is our understanding that this application for withdrawal of the Registration
Statement will be deemed granted as of the date that it is filed with the
Commission unless, within fifteen days after such date, the Company received
notice from the Commission that this application will not be granted.

If you have any questions regarding this application for withdrawal, please
contact Harry J. Proctor, Esq. of Solomon Ward Seidenwurm & Smith, LLP, legal
counsel to the Company, at (619) 231-0303.

                                    SVI SOLUTIONS, INC.

                                    By: /s/ Barry Schechter
                                        Barry Schechter, Chief Executive Officer