SecProbe.io

CORRESP
1
filename1.htm

      Global SEC Comment Response 9-26-05

    GLOBAL
      DIVERSIFIED INDUSTRIES, INC.

    1200
      AIRPORT DRIVE

    CHOWCHILLA,
      CA 93610

    559-665-5800

    September
      26, 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, 2005

    Dear
      Mr.
      Forgione:

    This
      will
      acknowledge receipt of your letter of comment dated September 19, 2005 with
      regard to the above referenced filing. Our response is as follows:

    1.
      In
      connection with the bill and hold arrangements, we are not obligated to perform
       installation
      services.

    2.
      Revenues
      in connection with installation services related to bill and hold arrangements
       are
      recognized when provided and accepted by the Customer. The Company’s wholly
 owned
      subsidiary, MBS Construction, provides this service to the Company’s modular
 structure
      customers as well as to non-modular structure customers, and is considered
      a
 separate
      unit of accounting and profit- center.

    The
      installation services have value to the customer whether the Company provides
      the installation, or a third party renders the service.

    The
      fair
      value of the installation service is objectively determined by comparing prices
      the Company charges to the prices other contractors charge. The price charged
      by
      the Company is established by management based upon their experience and prices
      charged by competitors in the marketplace.

    September
      26, 2005

    Mr.
      Josh
      Forgione

    Re:
      Global Diversified Industries, Inc.

    File
      No.
      333-8321

     Form
      10-KSB for Year Ended April 30, 2005

    Page
      2

    The
      arrangements with the customers include a general right of return since the
      customer has the right to require the installation to be corrected, or replaced
      if is not accepted.

    We
      agree
      to disclose our policies for accounting for installation services as required
      by
      EITF 00-21, paragraph 18 in future filings.

    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