SecProbe.io

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								December 22, 2005

Mail Stop 6010

H. Arthur Davis
President
Golden Valley Development, Inc.
1200 Truxton Avenue #130
Bakersfield, VA 93301

Re:	Golden Valley Development, Inc.
	Registration Statement on Form 10-SB
      Filed November 29, 2005
	File No. 0-51637

Dear Mr. Davis:

      We have the following comments to your filing.  Please file
an
amendment by January 17, 2005 to comply with our comments.  If you
cannot amend the filing by that time, you should consider
withdrawing
the filing before it becomes effective by operation of law.  You
could then refile when you are able to respond to the comments.
Please note that you should file the request for withdrawal by
January 26, 2005.

      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 or may not 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.

Form 10-SB

1. Please provide a complete facing page to this registration
statement with all information required by Form 10-SB, including
the
class of securities to be registered and the section of the
Exchange
Act under which the class is to be registered.  Also, with a view
towards disclosure, please tell us the purpose for filing this
registration statement at this time.

Description of Business, page 2

2. We note your disclosure in note 3 on page 18 that you were
incorporated by Tiger Team Technologies, Inc.  Please expand your
disclosure in this section to disclose the date and reason for
your
parent`s name change.

3. Please revise to explain Fresh Veg Broker`s business purpose
for
the August 2004 spin off.

4. Please revise to clarify whether you currently hold a PACA
license
to operate as a broker, when such license was obtained and its
duration.  If you do not currently hold a license, please disclose
this fact and discuss the applicable requirements under the PACA.

5. Please provide support for your statement that "Selling Broker"
is
a "recognized classification" under the PACA.

6. You state that your "main" job of "Selling Broker" is a
recognized
classification under the PACA.  Please expand your disclosure to
describe other aspects of your business.

7. Please expand your disclosure to explain the significance of
your
classification under the PACA as a fully accredited brokerage
business.  Address how this classification is obtained, including
what, if any, criteria must be met to obtain it, and any material
limitations such classification imposes on your business
activities.

8. Disclose the qualifications of your inspector to "guarantee"
high
levels of quality.  Explain whether there are established industry
criteria for measuring quality and whether the level of quality
guaranteed by your inspector conforms to such criteria.

9. If true, please disclose prominently that the transaction
discussed in the sixth paragraph is the only transaction you have
conducted since inception.  Where you refer to other business like
years of experience and multiple suppliers, please clarify that
you
are not describing the experience of Golden Valley.

10. Clarify how you know that your competitors do not inspect
produce.

11. Please describe in greater detail the nature and material
terms
of your alliance with Freymiller Trucking.  Disclose whether your
arrangement with Freymiller is in writing.  File the agreement.

12. Please clarify whether the customers you cite on page 3 are
customers of Golden Valley.

13. Please disclose any geographic scope of your business.  For
example, if you focus on central California customers, please
clarify
your disclosure accordingly.

14. Please reconcile your statement that you have no employees
with
your statement on page 2 about "our inspector."

Regulation, page 3

15. Please confirm, and provide us evidence, that your
accreditation
with the U.S. Department of Agriculture is current.

Management`s Discussion and Analysis, page 3

16. Please describe the material terms of the $50,000 loan from
Adavco, Inc.  Disclose whether the agreement is in writing and, if
so, please file as an exhibit.

17. Clarify what you mean by a loan for your "first 18 months and
for
the next 12 months."  Is this a loan to fund your first 30 months,
or
did you receive two loans?

18. Please expand your discussion of potential future business
models
to provide a more detailed description of your anticipated timing
for
these models and the feasibility of each model given your current
operations and resources.

19. Please describe the basis for your disclosure of a $15,000
cash
requirement.   See Regulation S-B Item 10(d)(3).

Marketing, page 3

20. We note that you have only conducted one transaction since
inception.  In various places throughout your document your
disclosure seems to indicate that you have conducted numerous
transactions.  For example, we note the reference in the first
paragraph on page 3 to happy "customers" and in the following
paragraph to "most of our brokerage deals."  Please revise the
disclosure throughout your document to clarify that you have only
conducted one transaction with a single customer.

Directors, page 5

21. Please disclose the nature of Andes River`s business.  Also,
with
a view toward disclosure, please tell us whether you compete with
Bakersfield Produce & Distributing and how you allocate business
opportunities between that company, Tiger Team and Golden Valley.

22. Please tell us why your directors` background does not explain
their experience with Fresh Veg Broker.com, Tiger Team, and Adavco
mentioned on page 3.

Certain Relationships and Related Transactions, page 6

23. We note that you utilize office space provided by a related
party
on a rent-free, month to month basis.  Please provide appropriate
disclosure in this section.

Voting rights, page 6

24. Disclose the number of votes per share.

Market Price, page 7

25. Please clarify why none of your shares may be sold pursuant to
Rule 144.

Recent Sales of Unregistered Securities, page 7

26. We note your disclosure that on July 26, 2004 you "sold" 40
million shares of common stock to Fresh Veg Broker.com in exchange
for a business plan valued at $40,000.  In Note 3, you disclose
that
Tiger Team Technologies "issued itself" 40 million shares at your
inception.  Please revise your disclosure to clarify how Tiger
Team
(formerly Fresh Veg Broker.com) acquired the shares it distributed
to
its shareholders.  File the agreements related to the
transactions.

27. Please tell us why the spin off was not registered under the
Securities Act.

Indemnification, page 7

28. The disclosure required by Regulation S-B Item 702 should not
be
qualified by "knowledge."  Please revise.

Financial Statements, page 8

General

29. Update the financial statements in accordance with Item 310(g)
of
Regulation S-B.  Please include any comparable interim periods of
the
preceding fiscal year with your updated interim statements of
income
and cash flows.

Statements of Expenses, page 9

30. Please tell us why this Statement does not include any
interest
expense during the periods presented.  We note your audited
Statement
of Income does include interest expense.  Revise this Statement as
necessary to include any interest expense incurred on your debt
during the interim periods.

Note 1 - Basis of Presentation, page 11

31. We note your reference to your "latest annual report filed
with
the SEC on Form SB-2."  Please tell us the file number and filing
date of this registration statement.

Statement of Income, page 14

32. Please revise this Statement to disclose basic and diluted
earnings per share as required by FASB Statement 128.

Notes to Financial Statements, page 17

Note 1 Summary of Significant Accounting Policies, page 17

General

33. It appears from disclosures in the "Marketing" section on page
4
you incur advertising expenses.  Please revise this Note to
disclose
your accounting policy for these expenses.  We assume it complies
with SOP 93-7.

Revenue Recognition, page 17

34. Your revenue recognition policy is too generic.  Please tell
us
and revise the note to explain the brokerage transaction and when,
in
the brokerage transaction, revenues are actually recognized.  We
note
you inspect the commodity before shipment.  Are there acceptance
provisions in your contracts that would affect revenue
recognition?
35. In a related matter, we note disclosures herein indicate you
act
as a broker without assuming the risks and rewards of ownership of
the goods, therefore sales are reported on a net basis.   It
appears
to us you have recorded transactions on a gross basis given
disclosures on page 2 that "you bought hay for $35,568 and then
sold
it for $43,568, for a profit of exactly $8,000".  Please tell us
how
you comply with EITF 99-19.  Also, revise the filing as necessary
to
clarify a reader`s understanding of how you present revenue
transactions in your financial statements and to eliminate the
referenced confusing disclosures.  We may have further comments
after
reviewing your response and revisions.

Note 3 - Common Stock, page 18

36. Please reconcile your disclosure to the information provided
under paragraph 4 of Certain Relationships and Related Parties,
page
6, wherein you indicate a business plan was purchased from Fresh
Veg
Broker.com, Inc for 40,000,000 Common shares.  Tell us and revise
the
filing to explain the following:
* the methods and assumptions used to value the stock,
* how you accounted for the transaction (discuss how SAB Topic
5(G)
impacts your required accounting) and
* the reason the share issuance resulted in a debit to additional
paid in capital in an amount equal to the value of the stock
issued.

Revise the filing as necessary based on our comment.  We may have
further comments after reviewing your response and revisions.

Note 5 - Commitments, page 18

37. We see you disclose you are using office space provided by a
related party on a rent-free, month to month basis.  Please tell
us
why your financial statements do not reflect an expense for the
fair
value of the monthly rent with an offsetting entry to donated
capital.  Note the guidance at SAB Topic 1(B)(1) requires the
financial statements to include all costs of doing business.

Index to Exhibits, page 19

38. We note that Exhibit 3 (Bylaws) is incorporated by reference.
It
is unclear why two sets of bylaws are filed as exhibits.  Please
clarify, and identify the document from which this exhibit is
incorporated by reference.

* * * * *

       As appropriate, please amend your filing and respond 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
Exchange Act of 1934 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.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* 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.

      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 our review of your filing or in
response to our comments on your filing.

	You may contact Dennis Hult at (202) 551-3618 or Jay Webb,
Accounting Reviewer, at (202) 551- 3603 if you have questions
regarding comments on the financial statements and related
matters.
Please contact Eduardo Aleman at (202) 551-3646 or me at (202)
551-
3617 with any other questions.

      Sincerely,

      Russell Mancuso
      Branch Chief

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H. Arthur Davis
Golden Valley Development, Inc.
December 22, 2005
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