TRANSFER AGREEMENT

   1
                                                                   EXHIBIT 10.28

                               TRANSFER AGREEMENT


Effective May 20th, 1999.

BETWEEN:

           ▇▇▇▇▇.▇▇▇ (ISLE OF MAN) LIMITED, an Isle of Man corporation
                                                                ("▇▇▇▇▇.▇▇▇")

AND:

         CYBEROAD GAMING CORPORATION, a St ▇▇▇ ▇▇▇▇ Indies corporation.

                                                                 ("Cyberoad")

1.    Cyberoad hereby agree to transfer 100% ownership of Ebanx Limited of
      Nevada USA to ▇▇▇▇▇.▇▇▇ for $10.00 US and other consideration hereby
      acknowledged as being received.

2.    This agreement may be executed in one or more counterparts, each of which
      shall be deemed an original and all of which shall constitute one and the
      same agreement.

                                  ACKNOWLEDGED

  ▇▇▇▇▇.▇▇▇ (ISLE OF MAN)                CYBEROAD GAMING CORP.

  Per:  /s/ ▇▇▇▇▇ ▇▇▇▇▇▇                 Per:  /s/ ▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇
      ------------------------------         ---------------------------------
  Name:    ▇▇▇▇▇ ▇▇▇▇▇▇                  Name:    ▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇
  Title:   Director                      Title:   Director