SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
Mail Stop 7010

							November 28, 2005

Gerald W. Williams
Chief Executive Officer
The Cavalier Group
12880 Railway Avenue, Unit 35
Richmond, British Columbia
Canada, V7E 6G4

	Re:	The Cavalier Group
      Amendment No. 3 to Registration Statement on Form SB-2
      Filed November 16, 2005
      File No. 333-127016

Dear Mr. Williams:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.  After
reviewing this information, we may raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Dilution of the Price You Pay for Your Shares, page 18

1. In the second paragraph under the caption, Dilution of the
Price
You Pay for Your Shares, it appears the number of shares purchased
by
the eight individuals was 2,400,000 rather than 1,200,000.  Please
revise.

2. We have read your response to comment 3 in our letter dated
October 26, 2005 and note your corrected financial disclosures.
However, it is not clear to us how you have calculated the post
offering net tangible book value for each of the three outcomes at
the bottom of the Dilution Table.  We assume this value is
calculated
by dividing the sum of the net proceeds and the net book value of
$14,077 by the total shares outstanding.  Please advise or revise
as
necessary.  Refer to Item 506 of Regulation S-K.

Plan of Distribution, page 20

3. We note your response to prior comment 4.  Please explain in
the
filing how Mr. West will be compensated for his service on the
board.

August 31, 2005 Financial Statements

Note 1: Basis of Presentation, page F-15

4. We have read your response to comment 5 in our letter dated
October 26, 2005.  However, the reference to a Form 10-KSB remains
in
this note.  As requested previously, revise your document
accordingly.

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities Act
of
1933 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to a company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

?	should the Commission or the staff, acting pursuant to
delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

?	the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

?	the company may not assert staff comments and the declaration
of
effectiveness as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the
United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Jenn Do at (202) 551-3743 or in her absence,
Nate Cheney at (202) 551-3714 if you have questions regarding
comments on the financial statements and related matters.  Please
contact Brigitte Lippmann at (202) 551-3713 or in her absence,
Chris
Edwards at (202) 551-3742 or me at (202) 551-3760 with any other
questions.

Sincerely,

Pamela A. Long
Assistant Director

cc:	Brian McDonald, Esq.
	5781 Cranley Drive
	West Vancouver, British Columbia
	Canada V7W 1T1
??

??

??

??

Gerald W. Williams
The Cavalier Group
November 28, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>