SecProbe.io

CORRESP
1
filename1.htm

      SEC Comment Response 8-4-05

    GLOBAL
      DIVERSIFIED INDUSTRIES, INC.

    1200
      AIRPORT DRIVE

    CHOWCHILLA,
      CA 93610

    559-665-5800

    August
      4,
      2005

    VIA
      FAX AND EDGAR

    Mr.
      Josh
      Forgione

    Division
      of Corporate Finance

    U.S.
      Securities & Exchange Commission

    Washington,
      D.C. 20549

    Re:
      Global Diversified Industries, Inc.

    File
      No.
      333-8321

     Form
      10-KSB for Year Ended April 30, 2004

    Forms
      10-QSB for quarters ended October 31, 2004

    Dear
      Mr.
      Forgione:

    This
      will
      acknowledge receipt of your letter of comment dated August 3, 2005 with regard
      to the above referenced filings. Our responses reference your comment numbers
      as
      follows:

    Comment
      1

    We
      have
      considered the various input methods and output methods to measure progress
      on
      contracts under SOP 81-1. The modular structures are not standardized,
      homogenous units that are mass produced, but rather each building plan is
      modified by contract per the Buyer’s specifications. We have prepared and attach
      a schedule of our six (6) basic plans which include the typical modifications
      and their related costs. We have also included a representative sample of the
      sales prices of the 24 x 40 PC# 02-105411 model , modified by the respective
      Buyers.

    As
      can be
      noted , the model’s sales prices can vary widely, from $47,498 to $113,356 per
      unit, depending upon the Buyer’s specifications. The direct costs incurred would
      also vary accordingly.

    Given
      the
      varying degree of effort that is devoted to each contracted modular structure
      resulting from the Buyers’ modifications, the Company’s management has chosen an
      input measuring approach (a combination of direct labor hours expended and
      raw
      materials used) to measure the progress of each contract.

    Management
      believes its experience in the industry provides it with the judgment needed
      to
      utilize this approach for measuring the progress on contracts.

    Comment
      2

    We
      have
      acknowledge the disclosure of our policy of not recognizing revenues until
      delivery of the modular structures had occurred in our April 30, 2004 financial
      statements was inaccurate. The Company’s policy has been to capitalized the
      direct costs (materials and direct labor) of its construction in progress by
      adjusting inventories at each balance sheet date, as represented by
      work-in-progress and finished goods, and recognizing the respective amounts
      as
      revenues.

    As
      of
      April 30, 2004, the Company’s work-in-progress and finished goods inventories
      represents the unbilled direct costs incurred as of April 30, 2004 of $ 402,023,
      which was included in income from operations during the year ended April 30,
      2004.

    The
      impact on the historical financial statements would be the reclassification
      of
      the amounts representing work-in-progress and finished goods inventories to
      a
      separate current asset account, costs
      in
      excess of billings on contracts of $402,023.
      There would be no impact on the statement of operations.

    In
      connection with the preparation of our April 30, 2005 financial statements,
      we
      will revise our disclosures as described in our letter of August 2, 2005,
      including separately disclosing costs incurred in excess of
      billings.

    Comment
      3

    The
      August 2, 2005 letter has been filed on EDGAR

    We
      thank
      you in advance for your assistance in this matter. Since we are in the process
      of preparing our financial statements in connection with the year ended April
      30, 2005 to be included in our Annual Report on Form 10K SB, we respectfully
      request an expedited review of our responses. If you have any questions or
      additional comments, please do not hesitate to contact us.

    Sincerely,

    GLOBAL
      DIVERSIFIED INDUSTRIES, INC.

    /s/
      Phillip O Hamilton

    __________________________

    Phillip
      O
      Hamilton

    Chairman
      & CEO