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      Global SEC Comment Response 8-25-05

    GLOBAL
      DIVERSIFIED INDUSTRIES, INC.

    1200
      AIRPORT DRIVE

    CHOWCHILLA,
      CA 93610

    559-665-5800

    August
      25, 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

    Dear
      Mr.
      Forgione:

    The
      will
      acknowledge receipt of your letter of comment dated August 18, 2005 with regard
      to the above referenced filing. Our response is as follows:

    The
      customer issues a purchase order to the Company for building(s) and any other
      services they have selected. The bill and hold agreements stipulate that when
      the building is complete and accepted by the customer, all our obligations,
      except for delivery and installation, under the purchase order has been
      completed and the purchase price is due and payable per the terms of the
      purchase order. Services rendered in connection with delivering the unit to
      the
      customer, such as transportation, off-loading the unit and installation are
      shown as separate line items in the Company’s quote issued and accepted by the
      Customer. The Customer has the option to hire our Company, other contractors
      or
      use their in-house staff for the transportation and installation. Freight and
      installations services are recognized as revenue when the service is
      rendered.

    The
      purchase price of the modular unit is payable by the Customer upon their
      irrevocable acceptance of the structure, there is no
      modification
      to the
      terms of the purchase order, such that, the purchase price is not payable until
      the delivery to the Customer’s location.

    Revenues
      recognized under bill and hold arrangements at April 30, 2003: $ -

    Revenues
      recognized under bill and hold arrangements at April 30, 2004: $ -

    Revenues
      recognized under bill and hold arrangements at April 30, 2005: $
      427,180

    We
      thank
      you in advance for your assistance in this matter. 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