Jody M. Walker Attorney At Law 7841 South Garfield Way Centennial, CO 80122 Telephone: 303-850-7637 Facsimile: 303-482-2731 December 15, 2009 Tia Jenkins Securities and Exchange Commission 100 F Street NE Washington, D.C. 20549 Re: Baynon International Corp Form 10-K for fiscal year ended December 31, 2008 filed March 19, 2009 File Number 000-000-26653 Dear Ms. Jenkins: In response to your letter dated November 6, 2009, please note the following: Form 10-K for the fiscal year ended December 31, 2008 Section 302 Certifications General 1. We note that your Section 302 certifications do not comply with the language required by Item 601(31) of Regulation S-K in the following respects: - You are missing paragraph 4(b) as required by Item 601(31) of Regulation S-K. - Paragraph 4(b) as disclosed indicates you conducted your evaluation of disclosure controls and procedures "as of a date w2ithin 90 days prior to the filing date of [your] report" versus as of the end of the period covered by your report, - The head note to paragraph 5 should include a reference to internal control over financial reporting. Please revise your certifications to comply with the issues above. The certifications have been revised. Other Exchange Act Filings 2. Please revise your Form s 10-Q for the quarters ended March 31, 2009 and June 30, 2009 to address our comment above regarding deficiencies in your Section 302 certifications. The certifications have been revised for all appropriate quarterly reports. Very truly yours, /s/Jody M. Walker - --------------------------- Jody M. Walker