SecProbe.io

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<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
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      August 16, 2005

Mail Stop 4561

VIA U.S. MAIL AND FAX (559) 665-7066

Mr. Phil Hamilton
President and Chief Executive Officer
Global Diversified Industries, Inc.
1200 Airport Drive
Chowchilla, CA  93610

Re:	Global Diversified Industries, Inc.
Form 10-KSB for the year ended April 30, 2004
      Filed August 17, 2004
      File No. 333-83231

Dear Mr. Hamilton:

      We have reviewed your response letter dated August 15, 2005
and
have the following additional comments.  Feel free to call us at
the
telephone numbers listed at the end of this letter.

1. Your response to comment 1 suggests that you engage in bill and
hold transactions from time to time.  Please list each of the
criteria in Question 3 to SAB Topic 13(A)(3) and tell us how you
considered these criteria when recognizing revenue on a bill and
hold
basis.  Please also expand your revenue recognition policy to
disclose how you qualify to recognize revenue on a bill and hold
basis.

2. Please file your August 15, 2005 letter on EDGAR in response to
this comment.

*  *  *  *

	You may contact Josh Forgione, at (202) 551-3431, or me, at
(202) 551-3403, if you have questions. Please respond to the
comments
included in this letter within 10 business days or tell us when
you
will provide us with a response.  Please file your response on
EDGAR.

								Sincerely,

      Steven Jacobs
      Accounting Branch Chief
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Mr. Phil Hamilton
Global Diversified Industries, Inc.
August 12, 2005
Page 1

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