SecProbe.io

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<TYPE>LETTER
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<FILENAME>filename1.txt
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      August 18, 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 16, 2005
and
have the following additional comments.  Feel free to call us at
the
telephone numbers listed at the end of this letter.

1. We read your response to comment 1.  Please tell us how you
considered the fifth criteria in SAB Topic 13(A)(3)(a) in light of
your obligation to perform installation services which we
understand,
based on prior discussions with you, represent approximately 10%
of
the total cost.  In addition, tell us when the purchase price is
payable by the buyer and whether there is any modification such
that
the purchase price is not payable until delivery is made to the
final
site.  Please also quantify for us the amount of revenue
recognized
on a bill and hold basis at April 30, 2005, 2004 and 2003.

*  *  *  *

	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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