Mail Stop 04-06

December 29, 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 December 17, 2004
      File No. 000-30801

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 comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.
1. To the extent that you make changes to the Form 8-K to comply
with
our comments, please obtain and file an updated Exhibit 16 letter
from the former accountants stating whether the accountant agrees
with the statements made in your revised Form 8-K.
2. Amend to state, if true, that the date of resignation was
November
27, 2004 and extend the interim period from the date of the last
audited financial statements to the date of resignation.  See Item
304(a)(1)(IV) of Regulation S-K.
3. Amend to disclose any consultations with your new accountants
up
through the date of engagement, November 27, 2004.

       As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  Please furnish a cover letter with your
amendment
that keys your responses to our comments and provides any
requested
supplemental information.  Detailed cover letters greatly
facilitate
our review.  Please understand that we may have additional
comments
after reviewing your amendment and responses to our comments.

	 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 comments, 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
??

??

??

??

MIAD Systems, Ltd.
December 29, 2004
Page 2