SecProbe.io

Mail Stop 3561

        October 25, 2005

Via U.S. Mail and Facsimile [(416) 594-6811]

Mr. Ross McGroarty
Chairman/Secretary
Byron Global Corp.
2045 Lakeshore Blvd. W., Suite 3903
Toronto, Ontario M8V 2Z6
Canada

Re:   Byron Global Corp.
 Form 6-K/A for the quarter ended June 30, 2005
 File No. 000-30194

Dear Mr. McGroarty:

We have reviewed your response letter dated September 14, 2005, and the associated
amendment, and have the following comments.  If you disagree, we will consider your
explanation as to why our comment is not applicable or a revision is unnecessary.  We also ask
you to provide us with supplemental information so we may better understand your disclosure.  Please be as detailed as necessary.  We look forward to working with you in these respects and
welcome any questions you may have about any aspects of our review.

Please respond to confirm that the comment will be complied with, or, if the comment is deemed
inappropriate by the Company, advise the staff of the reason thereof.  Pursuant to Rule 101(a)(3)
of Regulation S-T, your response should be submitted in electronic form, under the label
“corresp” with a copy to the staff.  Please respond within ten (10) business days.

* * * * * * *

Mr. Ross McGroarty
Byron Global Corp.
October 25, 2005
Page 2

Form 6-K – Amended
For the quarter ended June 30, 2005 (Q2)
Statement of Stockholders’ Equity, page 3

1. Please refer to comment 1 from our letter dated August 4, 2005, as we do not believe the
adjustments to your Form 6-K – Amended, as filed on October 14, 2005, have complied
with our comment.  We note that you have recorded a write down to your marketable
securities, due to the impairment of your investment in Ontex Resources Limited, by recording a decrease of $26,394 to other comprehensive income.  As previously
discussed, it appears that the Ontex investment has suffered an other than temporary
impairment, as no evidence to the contrary has been provided.  In this regard, the appropriate accounting treatment would be to record the entire decline in fair value as a
realized loss, with the amount of the write down included in earnings in the statement of
operations, pursuant to paragraph 16 of SFAS 115.  Your adjustment to other
comprehensive income implies that the investment has suffered a temporary impairment,
and would not be appropriate for an investment that has experienced an other than
temporary decline in fair market value.  Please revise your June 30, 2005, statement of operations in an amendment to Form 6-K accordingly, taking into account the following
comment regarding the amount of the adjustment.

Note 8.  Subsequent Event, page 9

2. We note your disclosure stating that the Ontex shares were transferred on August 15,
2005, for a market value of $82,500.  As such, please provide a breakdown as of June 30,
2005, of your marketable securities balance, and the analysis that you used to determine
the fair value of the Ontex investment at that date.  Your response should include an explanation of any events subsequent to June 30, but prior to your disposing of the
shares, that may have further affected the fair market value of the shares.  It appears that
the fair market value of the shares on June 30, 2005 should not be materially different from their value on August 15, 2005.  However, the carrying value of the shares as of
June 30, 2005 appears to be significantly higher than their value of $82,500 on August
15, 2005.  Please advise, and revise accordingly.
3. In addition, please provide us with your accounting treatment for the share transfer, and reduction in note payable, on August 15, 2005.

* * * * * * *

Mr. Ross McGroarty
Byron Global Corp.
October 25, 2005
Page 3

You may contact Ms. Kristin Shifflett, St aff Accountant, at (202) 551-3381, if you have
questions regarding comments on the financial statements and related matters.  Please contact me
at (202) 551-3816 with any other questions.

Sincerely,

Joseph Foti
       Senior Assistant Chief Accountant