SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C.  20549

         DIVISION OF
    CORPORATION FINANCE

April 1 5, 2020

Egor Roman yuk
Barna Capital Group Ltd.
Panagioti Symeou 2
Block C, Suite 4
Limassol, Cyprus, 3105

 Re: YRC Worldwide , Inc.
Schedule 1 3D and Schedule 13D/A beneficial ownership report  filing s
Filed on March 17 and April 9 , 2020 by Barna Capital Group Ltd.
  File No.  005-36095

Dear M r. Romany uk,

We have reviewed the above -captioned  filing s, and have the following comments.   Some
of our comments may ask for additional information so that we may better understand the disclosure.

  Please respond to this letter by amending the filing s and/or by providing the requested
information.  If you do not believe our comments apply to your facts and circumstances , and/or do
not believe an amendment is appropriate, please tell us why in a written  response.  After reviewing
any amendment s to the filing s or any information provide d in response to these comments, we may
have additional comments.

Schedule 1 3D filed on March 17, 2020

1. The Schedule 13D indicates that Barna “may be deemed  to be the beneficial owner of
1,750,000 shares of Common Stock. Such 1,750,000 shares represent approximately  5.2% of
the outstanding shares of Common Stock.”  As disclosed  by the Co mpany on the cover of its
Annual Report on Form 10 -K, File No. 000 -12255,  filed on March 11, 2020 (the most recent
publicly available report of the number of  outstanding shares of Common Stock prior to the
filing of the Schedule 13D), there  were 36,081,170  shares of Common Stock outstanding at
March 6, 2020.   Accordingly, as of the date that the  Schedule  13D was filed with the
Commission, Barna’s ownership stake represented  only approximately 4.85% of the
outstanding shares of Common Stock when calculated in accordance with Rule 13d -1(j).
Please advise us, with a view toward amending the Schedule 13D to report that  Barna was
not previously the beneficial owner of more than five percent of the shares  of Common
Stock, how the original calculation of the ownership percentage reported was performed.

2. Please advise us, with a view toward revised disc losure, why you, Mr. Egor Romany uk, have
not appeared as a joint filer  within this S chedule 13D beneficial ownership report given that
even a person who indirectly shares the power to direct another person to vote or dispose of
shares is considered a beneficial owner under Rule 13d -3(a) of Regulati on 13D -G.

Egor Rom anyuk
Barna Capital  Group Ltd.
April 1 5, 2020
Page 2

 3. Item 2 of Schedule 13D provides information interchangeably at times between Barna
Capital and Mr. Egor Romanyuk .  For example,  Item 2(c) and Item 2(f) provide  disclosures
with respect to Mr. Romanyuk and not Barna.  Consequently, either (i) the  Schedule 13D and
Amendment No. 1  are deficient for failing to comply with Item s 2(c) and  (f) of the Schedule
13D and i nstructions thereto, or (ii) such filings are deficient for  failing to disclose that Mr.
Romanyuk is a reporting person and to provide the  information called for by th e Schedule
13D with respect to Mr. Romanyuk  in his capacity as a joint beneficia l owner .  Please revise
the Schedule 13D , or advise us why Barna Capital believes n o modifications are necessary.

4. Compliance with Item 5(c) of the Schedule 13D and the instructions thereto require the
beneficial owner to describe (i) the person who effected the purchase(s) of Common Stock,
(ii) the date of  such transaction( s), (iii) the amount of securities involved, (iv) the price per
share, and  (v) where and how the transaction(s) was effected.   Please advise us, with a view
toward revised disclosure, how compliance with this provision was effectuated.

5. Item 5(d) of Schedule 13D  requires disclosure of  “any other person [who] is known to  have
the right to receive or the power to direct the receipt of dividends from, or the  proceeds from
the sale of, such securities ” and “if such interest relates to more than [5%]  of the  class, such
person should be identified.”   No disclosure has been provided.  Negative response s to line
items , inclusive of a det ermination that the r equirement is inapplicable,  are required pursuant
to Instruction A of Schedule 13D.  Please revise to include the omitted information.

6. The name of the issuer in which the  beneficial ownership  is reportedly held is  YRC
Worldwide Inc. , not “YRC Wolrdwide Inc.”  In addition, the Schedule 13D and the  Schedule
13D/A incorrectly indicat e that the Company is incorporated in Nevada.   YRC  Worldwide  is
incorporated in Delaware.   Separately, please reconcile the inconsistencies of the spelling of
your last name on the  front cover page where the letter “y” has be en included and the
signature pa ge which substitutes a different letter in place of “y.”  Please ensure that all of
these oversights  are corrected in an amended filing .

7. To the extent that the March 17, 2020 Schedule 13D was filed in error or , alternatively,  a
conscious decision was made to voluntarily make the f iling, please revise t o disclose that
Barna Capital Group was not legally required to make the  March 17 Schedule 13D filing
with respect to its  beneficial  ownership of YRC Worldwide, Inc. ’s common s tock.

8. Please a dvise  us how  the date  of the event  that required the filing to be made  was identified .

Schedule 13D/A  filed on Schedule 1 3D/A on April 9 , 2020

9. Please advise us  how the date of the event identified on the front cover page was identified,
and how exactly the purported 5.4% level of beneficial ownership wa s calculated.  In
addition, please confirm that any amended Schedule 13D also takes into account all of our
observations made on  the initial  beneficial ownership report made on March 17, 2020.

Egor Rom anyuk
Barna Capital  Group Ltd.
April 1 5, 2020
Page 3

 Compliance with Section 14(a) and Regulation 14A

10. Postings on social media website Twitter made on April 11, 13 and 14, 2020, criticize YRC
Worldwide existing board members , purport to have three superior director candidates in
waiting, and claim  that Barna Capital Group has  received the suppor t of a labor union.   It
appears that each of these  communications constitutes  a solicitation as defined in Rule 14a -
1(l)(1)(iii) of Regulation 14A.  These communications  were made in advance of a proxy
statement filing and public ly distributed  in apparent contravention of Section 14(a) and Rule
14a-3(a) of Regulation 14A.   Please advise us why no proxy statement filing has been made.

 We remind you that all beneficial owners are  responsible for the accuracy and adequacy
of their disclosures, notwithstanding any review, comments, action or inaction by the staff.

  You may contact me at (202) 551 -3266 with any questions.

Sincerely,

        /s/ Nicholas P. Panos

Nicholas  P. Panos
Senior Special Counsel
Office of Mergers & Acquisitions