SecProbe.io

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                       SICHENZIA ROSS FRIEDMAN FERENCE LLP
                 1065 AVENUE OF THE AMERICAS   NEW YORK NY 10018
                TEL 212 930 9700 FAX 212 930 9725   WWW.SRFF.COM

                                   December 2, 2005

Wilson K. Lee
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Mail Stop 4561

     RE:     GLOBAL REALTY DEVELOPMENT CORP.
             FORM 10-KSB FOR THE YEAR ENDED 12/31/2004
             FILED 5/19/2005
             FORM 10-QSB FOR THE PERIOD ENDED 3/31/2005 AND 6/30/2005
             FILED 5/23/2005 AND 8/19/2005
             FILE NO. 000-32467

Dear Mr. Lee:

     The  following responses address the comments of the reviewing Staff of the
Commission  as  set forth in a comment letter dated October 18, 2005 relating to
the Form 10-KSB for the year ended December 31, 2004 and the Form 10-QSB for the
period  ended  March  31, 2005 and for the period ending June 30, 2005 of Global
Realty  Development  Corp. (the "Company"). On behalf of the Company, we respond
as follows:

FORM 10-KSB FOR THE YEAR ENDED DECEMBER 31, 2004
------------------------------------------------

FINANCIAL STATEMENTS AND NOTES
------------------------------

GENERAL
-------

1.   We  have  read  your  response  to  comment one. We noted that as a part of
     the reverse merger with the public shell, you combined the three individual
     private  companies owned by the same individual shareholder, eliminated the
     combined equity of the private companies and replaced it with the equity of
     the publicly traded company. Since the reverse merger created a new capital
     structure  for  you,  please explain the basis for presenting the financial
     statements on a combined instead of consolidated basis.

     Answer
     ------

     The  Company  titled  the  financial  statements  "combined"  rather  than
     "consolidated"  because  prior  to the reverse merger none of the companies
     had  a  controlling financial interest in the voting stock of the other two
     companies.  Our  understanding  of  ARB 51 leads us to conclude titling the
     financials  combined  rather  than consolidated was more informative to the
     reader.  As  a  practical matter, the accounts were added together at their
     carrying values except no investment account was eliminated and the capital

<PAGE>

     section  was  replaced  with  the capital section of the public company. We
     believe  this  title  best  presents  the  spirit  of  recent  developments
     concerning  business  combinations  and  consolidated financial statements.
     Future statements will be titled "consolidated."

2.   Please  explain  to  us  how  you  accounted  for  the  combination  of the
     three  individual private companies before the merger with the public shell
     arid  your basis in GAAP for this accounting treatment. Please identify, if
     applicable,  the controlling person, entity or group and explain your basis
     for  this  conclusion.  Refer  to  the guidance in ARB 51 and EITF 02-5 and
     paragraphs D11 to D18 of SFAS 141.

     Answer
     ------

     The  three  separate  entities  maintained  separate accounting records for
     the entire term of the financial statements presented, years 2003 and 2004.
     The  accounts were then combined (consolidated) for the Report and reported
     as  called  for  under  Section  D12 of SFAS 141 at the respective carrying
     amounts of the individual entities. The results of operations were reported
     as  though  the  transfer occurred at the beginning of the period as called
     for under Section D16 of SFAS 141.

COMBINED STATEMENT OF STOCKHOLDERS' EQUITY, PAGE 18
---------------------------------------------------

3.   We    have   read   your   response  to  comment   two.   The   consultants
     subsequently  sold  the stock issued and you based the compensation cost of
     the  issuance  on the sales price of the stock at time of sale. Tell us how
     this  valuation is supported by the guidance in paragraph S of SFAS 123 and
     EITF 96-18.

     Answer
     ------

     Based  upon  the  Company's  reading  of  EITF  96-18,  they concluded that
     although  the commitment to perform services and the date when the services
     were  complete preceded the sales of the stock, given the relatively little
     activity  in the stock the selling price of the consultants' shares gave us
     the  best possible measurement date. Additionally, the stock was selling at
     $0.50  per  share  during the third quarter 2004. This price was similar to
     the  price  used. The share exchange agreement was dated September 4, 2004.
     We  felt  additional comfort in this conclusion, given the limited activity
     of  the  Company  between  the  date  the  Company  committed  to  pay  the
     consultants and the date the consultants' stock sale took place.

NOTE B - SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES
---------------------------------------------------

LAND OPTIONS, PAGE 21
---------------------

4.   We  have  read  your  response  to  comment  three. We noted that you pay a
     non  refundable  deposit  down for agreements to purchase property. Tell us
     how  you  considered  paragraphs 5, 14, and 15 of FIN 46 (R) in determining
     your  accounting of the non refundable deposit options. Also, we noted that
     you  book  the  entire  contract  price to land inventory with an offset to
     accounts payable. Tell us the basis in GAAP for recording these amounts. In
     addition, for each of the options described in your footnote (e.g. specific
     performance  options,  options  with  variable interest entities, and other
     options),  please  explain  the major terms of the options and quantify the
     amount recorded on the financial statements.

     Answer
     ------

<PAGE>

     As  explained  in  one  above,  the  Company  has  consolidated  the  three
     entities.  The  Company  believes  that  with  almost 20 million dollars in
     equity,  it  has  the  ongoing  ability  to  finance its activities without
     additional  substantial  support  from  outside parties. This is especially
     true  given the fair market values currently and anticipated of land in the
     Melbourne,  Australia market. The recipients of the non-refundable deposits
     were  a  Country  Club,  individually  owned farm, and individuals, Even if
     these  were construed to be VIE's under FIN 46 (R), they have no obligation
     to  absorb  a  majority  of  the  Company's expected losses (if any) or are
     entitled  to receive a majority of the entities' expected returns. As such,
     the Company did not consider it to be a primary beneficiary of the sellers.
     It therefore concluded, after due consideration of FIN 46R, that there were
     no  VIEs  to  be  consolidated  as  of December 31, 2004 or 2003. Since the
     Company  entered  into  binding  contracts  with  the  sellers, the Company
     believes under APB 21 this obligation arose from transactions in the normal
     cause of business and as such, should be recorded as accounts payable.

     To  date,  the  Company  has   not   yet  utilized  the   various   options
     possibilities in any business transactions. This disclosure was intended to
     demonstrate  how  the  accounting  will  be handled should such alternative
     financing options arise in the future. The Company intends however, to omit
     this wording in future filings to avoid confusion unless these transactions
     ever occur.

POST DEVELOPMENT COMPLETION COSTS, PAGE 21
------------------------------------------

5.   We   re-issue   comment  four   from  our  pervious  comment  letter.  With
     respect  to those instances in which you have post development construction
     obligations  relating  to  sold  developments, please explain to us how you
     considered paragraph 46 of SFAS 66 in your accounting for these sales.

     Answer
     ------

     Similarly,  the  operations  of  the  Company  have  not  yet progressed to
     completion  of  projects  subject  to  any  liability  for post development
     completion costs. This footnote is also intended to provide the reader with
     the  accounting  policies  that  will be utilized in future periods. Profit
     will  be recognized under the full accrual method for sales when conditions
     a,  b,  c  &  d  of  paragraph  46 of FAS 66 are met and the Company is not
     obligated  to  complete any future improvements or construct any additional
     amenities or facilities.

     In  connection  with  the  foregoing  responses  we  hereby acknowledge the
following on behalf of the Company:

     o    the  Company  is  responsible  for  the  adequacy  and accuracy of the
          disclosure in the filing;
     o    staff  comments  or  changes  to  disclosure  in   response  to  staff
          comments  in  the  filings  reviewed by the staff do not foreclose the
          Commission from taking any action with respect to the filing; and
     o    the  Company  may  not  assert  staff  comments  as  a  defense in any
          proceeding initiated by the Commission or any person under the federal
          securities laws of the United States.

                                       ***

     Should  you  have  any further questions, please do not hesitate to contact
the undersigned at (212) 930-9700

     Sincerely,

                              /s/ Yoel Goldfeder
                              ------------------
                              Yoel Goldfeder

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