Mail Stop 04-06

      December 8, 2004

Via facsimile to (905) 479-9472 and U.S. Mail

Michael A.S. Green
President
MIAD Systems, Ltd.
43 Riviera Drive, Unit 6
Markham, Ontario L3R 5J6
Canada

Re:   	MIAD Systems, Ltd.
      Form 8-K filed November 17, 2004
      File No. 003-30801

Dear Mr. Green:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comments are inapplicable or a revision
is
unnecessary. Please be as detailed as necessary in your
explanation.
After reviewing this information, we may or may not raise
additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 8-K filed on November 17, 2004
1. In your previous Form 8-K filings you reported that Brodeur,
Dennis Chartered Accountants resigned effective April 23, 2004.
We
note, however, that your Form 10-QSB for the quarterly period
ended
June 30, 2004 contains a Review Report signed by Brodeur, Dennis
Chartered Accountants which is dated August 16, 2004.  Please
clarify
for us if and when the relationship with Brodeur ceased and why
you
have not previously disclosed the continuance of the relationship.
If Brodeur was re-engaged, an additional Form 8-K was required for
both the re-engagement and the second resignation. Please advise.
We
may have further comment.

General

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comment, please provide,
in
writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      Please file your supplemental response and amendment via
EDGAR
in response to these comments within 10 business days of the date
of
this letter.  Please note that if you require longer than 10
business
days to respond, you should contact the staff immediately to
request
additional time.  Any questions regarding the above should be
directed to me at (202) 942-1987, or in my absence, to Robert
Benton
at (202) 942-1811.


Sincerely,



Tamara Tangen
      Staff Accountant
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MIAD Systems, Ltd.
December 8, 2004
Page 2