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

October 31, 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/A
         Filed October 20, 2008
         File Number: 333-153510

To Whom It May Concern:

In response to your letter dated  October 29, 2008,  Silver Bay  Resources  Inc.
wishes to address the following comment.

FORM S-1

1. We have removed from the Prospectus the following statement, "However, due to
the fact that the Company will not receive any of the proceeds of the  offering,
this offering is not a primary offering by or on behalf of the Company."

2.  We  have  removed  the  reference  to  "convertible   debentures"  from  the
Calculation of Registration Fee table.

3. We have removed the plural  references to "founders" and replaced it with the
singular reference to "founder".

4. We have amended the cost relating to the  registration  of common shares from
$65,000 to the more accurate cost of $6,240.39.

5. We have clarified the  registration in regards to the information and unclear
dates of the loan for  $60,000.  The loan was  executed  and  signed on June 15,
2008. As of July 31, 2008 the balance sheet shows this loan as outstanding  with
a balance of $60,000.  The document has been amended to clarify these dates when
and where the loan is referenced.

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