Subject: File No. 4-500
From: Ross McGroarty, Chairman
Affiliation: Byron Global Corp.

May 2, 2005

3903 – 2045 Lakeshore Blvd. West
Toronto Ontario, M8V 2Z6
Tel: 416 594 0528 Fax: 416 594 6811
Symbol: “BYRGF”

Jonathan G. Katz
Secretary, Securities Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

RE: SEC File No. 4-500. Request for Rulemaking Regarding Member Records of "Short" Positions and Reporting and Public Dissemination of Aggregate Positions by Security.

Dear Mr. Katz,

We are writing to you, for your consideration regarding a very important rule change that is needed to improve the marketplace for small issuers traded on the Pink Sheets and the OTCBB.

The importance of improving the Pink Sheets and OTCBB trading is paramount.

There is a crisis facing the OTC market today in the lack of short sale position reporting and disclosure for OTC issues. This lack of transparency regarding short selling in the OTC market allows fraudulent acts to go undiscovered and manipulative short sellers to hide.

WE believe regulators should fix the problem. Small issuers traded on the Pink Sheets and the OTCBB deserve the same transparency and regulatory oversight of short selling as those listed on Exchanges or NASDAQ.

Accordingly, we support the Pink Sheets petition to the SEC to cause the amendment of NASD Rule 3360 and require NASD broker dealers to maintain a record of total "short" positions in all customer and proprietary firm accounts in all publicly traded equity securities as well as report this information to the NASD for public dissemination of the short positions by security. The SEC's action is urgently needed to prevent fraudulent acts, expose market manipulation, promote fair principles of trade and protect investors.

Yours truly,

Ross McGroarty, Chairman

Cc. Barbara Z. Sweeney
Senior Vice President and Corporate Secretary, NASD
1735 K Street, NW
Washington DC 20006-1500;

Cc. R. Cromwell Coulson
Chairman & CEO, Pink Sheets