SILVER BAY RESOURCES INC.
                               4133 Stanford Ave.
                                Dallas, TX 75225
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VIA EDGAR ONLY

October 20, 2008

United States Securities and Exchange Commission
Washington D.C. 20549
Mail Stop 3561

Attention: Norman Gholson and Anne Nguyen Parker

     Re: Silver Bay Resources Inc.
         Registration Statement on Form S-1
         Filed September 17, 2008
         File Number: 333-153510

To Whom It May Concern:

In response to your letter  dated  October 3, 2008,  Silver Bay  Resources  Inc.
wishes to address the following comment.

FORM S-1

1. The Form S-1 has been revised  throughout the document to reflect that due to
the fact that that the  Company  will not  receive  any of the  proceeds  of the
offering,  the offering is not a primary offering by or on behalf of the Company
with Mr.  Gardner  acting as an  underwriter.  We have  accordingly  revised our
disclosure throughout the prospectus to make this clear.

2.  We  have  removed  the  phrase  "upon  conversion  of  outstanding   secured
convertible  debentures"  from Footnote 2 to the Calculation of Registration Fee
table on the Form S-1 cover  sheet,  as the Company  has not issued  convertible
debentures.

3. We have  corrected  the  references of  "founders"  (plural) and  "promoters"
(plural) to "founder"  (singular) and  "promoter"  (singular) as our Company has
only one founder and promoter.

PROSPECTUS COVER PAGE

4. We have named the  underwriter/sole  selling shareholder on the cover page of
the prospectus, and disclosed that he is our sole executive officer and director
and currently holds 100% of our common stock.

5. We have omitted the statement  "These  securities are offered  pursuant to an
exemption from registration with the Commission; however, the Commission has not
made an  independent  determination  that the securities  offered  hereunder are
exempt from  registration."  Given that the Company is registering the offering,
the Company is therefore not offering these securities pursuant to an exemption.

6. We have  amended  our  offering  costs  to a total  of  $6,240.39,  which  is
reflective of the actual cost we have incurred with respect to this filing.

DETERMINATION OF OFFERING PRICE, PAGE 14

7. We have  amended the phrase in question to read:  "The shares of common stock
covered by this  prospectus  will be offered for sale at a fixed price of $0.001
per share."

MANAGEMENT'S  DISCUSSION  AND  ANALYSIS OF  OPERATION  -  LIQUIDITY  AND CAPITAL
RESOURCES, PAGE 22

8. We have enhanced our  disclosure to reflect the terms of the loan of $60,000,
and have filed the agreement as an exhibit to our registration statement.

TRANSACTION WITH RELATED PERSONS, PROMOTERS AND CERTAIN PERSONS, PAGE 24

9. We have  amended  our  disclosure  to  indicate  that  we have  entered  into
agreements  with our  founder  with  respect to the  issuance  of shares and the
provision of a $60,000 loan.

We trust that  everything  is in order.  If you have any  questions or concerns,
please feel free to contact us anytime.

Very truly yours,


/s/ Donald R. Gardner
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DONALD GARDNER