VIRAGEN INC, RW, 1999-03-15

VIRAGEN INC
RW, 1999-03-15
BIOLOGICAL PRODUCTS, (NO DIAGNOSTIC SUBSTANCES)

Previous: INTERSTATE ENERGY CORP, 35-CERT, 1999-03-15

Next: VARIABLE ANNUITY LIFE INSURANCE CO SEPARATE ACCOUNT A, 497, 1999-03-15



<PAGE>   1
                                                                  March 15, 1999

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549

         RE:      VIRAGEN, INC. (THE "COMPANY") - REGISTRATION STATEMENT
                  ON FORM S-3 - FILE NO. 333-65119

Dear Sir/Madam:

         Reference is made to the above Registration Statement. On behalf of the
above Registrant, the Company does hereby withdraw the above Registration
Statement. Based on comments received by the Staff, we believe that it will be
in the best interest of the Company to withdraw the Registration Statement.

         No resales of any of the securities intended to be resold under such
Registration Statement have been made by any person.


                                                     Very truly yours,

                                                     James M. Schneider

JMS/bb
cc:      Viragen, Inc.
         Swartz Investments, LLC