SecProbe.io

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Mail Stop 6010	April 3, 2006

Mr. Charles Godels
President
Avalon Development Enterprises, Inc.
770 First Avenue North
St. Petersburg, Florida  33701

Re:	Avalon Development Enterprises, Inc.
	Amendment No. 3 to Registration Statement on Form SB-2,
		filed March 24, 2006
	File No. 333-130937

Dear Mr. Godels:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your documents 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
supplemental 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General

1. We note your response to our prior comment 2 and that you
deleted
your statement that Mr. Godels has been "involved" in many
property
acquisitions as a CPA.  Our comment concerns whether it is
appropriate for you to conclude that you have a "proven background
of
property acquisition demonstrated by our officers and
directors...."
Since you have not provided supplemental support concerning the
statement regarding a proven background, you should revise your
disclosure to delete this statement.

Risk Factors

(2) We may not be able to fully implement our business plan due to
our limited experience in commercial building maintenance and
cleaning, page 2

2. We note your response to our prior comment 7 and your added
disclosure that your revenue in 2005 was from your cleaning
services.
You still make the statement that, "None of our revenue is from
related entities" in this risk factor.  Because your rental income
to
date was from a related party, please delete this statement.
Please
also revise your disclosure to state that you have no revenue to
date
for maintenance services.

(3) We Have Generated Minimal Profits Since Inception . . . .Pages
2-
3

3. We note your response to our prior comment 9 and reissue that
comment in part.  Please revise to disclose that Mr. Godels also
owns
50% of the equity of Godels, Solomon Barber, & Company L.L.C.
Please
also disclose this elsewhere in the prospectus where you discuss
any
transactions between the company and Godels, Solomon Barber, &
Company L.L.C.

(5) Our Competitors Have Greater Financial Resources than We Do .
. .
. Page

4. We note your response to our prior comment 10 and reissue that
comment in part.  Please provide a detailed and robust discussion
of
Mr. Godels experience of commercial building leasing in the
business
section of the prospectus.

(6) There are Relationships . . . . Page 4

5. We note your response to our prior comment 11 and reissue that
comment.  Please explain what you mean by properties that "exceed
what we have established as our target market."

6. We note your statement that you "believe [Mr. Godels`] contacts
are in the real estate industry, mortgage brokerage industry as
well
as banking."  It is unclear to us why you would not definitely
know
where these contacts exist.  Please explain or revise to delete
the
reference to "believe."

(8) We Have No Set Minimum of Shares . . . . Page 4

7. Please revise this risk factor subheading so that it reflects
the
risk discussed in the text.

Business

8. We note your response to our prior comment 13 and your revised
disclosure that Mr. Godels has one key relationship in the banking
industry and in excess of 500 other professional contacts.  Please
provide us your analysis, on a supplemental basis, as to why the
identity of this one key contact in the banking industry is not
material information and should not be disclosed in the
prospectus.

9. We note your response to our prior comment 18 and reissue that
comment in part.  Regarding the sale of shares on the date you
transferred the property, please disclose the aggregate number of
shares sold and the aggregate proceeds received.  Also, please
explain what you mean by additional paid in capital of $102.

10. We note your response to our prior comment 21 and your revised
disclosure in the Certain Relationships and Related Transactions
section that the $400,000 valuation was determined by Mr. Godels.
Please revise your disclosure in this section as well to clarify
that
the $400,000 valuation was determined by Mr. Godels.

11. We note your response to our prior comments 22 and 23.  You
state
that when the building was transferred, Godels Solomon Barber &
Company, L.L.C. moved its offices to a new location at 5113
Central
Avenue, St. Petersburg, Florida and that you relocated your office
to
the same building.  Did the move to 5113 Central Avenue occur on
August 2, 2004 when you transferred the 770 1st Avenue property to
Bahia Shores?  When you filed the original prospectus on January
9,
2006, your disclosure indicated that your office is located at 770
1st Avenue.  Please explain.  Your disclosure should provide dates
and a clear explanation.

12. We note your response to our prior comment 25 and reissue that
comment.  You still have not provided a robust discussion of how
your
President customizes financial strategies for clients through the
use
of real estate.

13. Please clarify what you mean by the statement, "None of his
relationships could be considered to be private and not available
to
the general public at large."

Management`s Discussion and Analysis of Financial Condition and
Plan
of Operations

Results of Operations

General, page 22

14. We note your response to comment 27.  In the paragraph that
immediately precedes "Table 6.0 Revenues, Expenditures and Net
Income" on page 24 you make the following statement, "our revenues
since January 1, 2003 have been generated from rental income."
This
statement does not appear to agree with your current revenue
streams
and other discussions.  Please revise it to more accurately
describe
your current operations.

Liquidity and Capital Resources, page 27

15. We note your response to our prior comment 28.  Please revise
your disclosure to state that it is your belief that the real
estate
market trend has shown a steady increase in both the demand for
such
buildings and the rate at which such buildings are appreciating in
value.

Financial Statements - December 31, 2005

Note F - Earnings per Common Share, page F-8

16. We note your response to comment 32 and the changes that you
have
made to the December 31, 2004 financial statements.  However, all
references and disclosures that include per share amounts should
reflect the restated share amounts.  Specifically these include:
* the shares outstanding in the balance sheet for 2003;
* the EPS in the income statement for 2004 and 2003;
* the amounts disclosed in the statement of shareholders` equity
for
2005, 2004, and 2003 as of the beginning of each period not at the
end per your current presentation;
* all EPS and share amounts disclosed in Note F for 2005, Note G
for
2004, and Note F for 2003;
* and Note G for 2005 should make it clear that all of these
amounts
have been retroactively restated to reflect this stock split
similar
to Note H for 2004, and a similar note should be added to 2003.

Financial Statements - December 31, 2004

Note F - Fixed Asset Dispositions, page F-15

17. We note your response to comment 33.  We are unable to locate
the
revised disclosures that discuss the circumstances that led to the
transfer of the property as well as the impact that this transfer
will have on your operations in the notes to financial statements.
Please revise your presentation to include this information or
provide a page reference to us of where to find this disclosure.

*	*	*	*	*

      As appropriate, please amend your filing 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 supplemental information.  Detailed cover letters
greatly facilitate our review.  Please file your cover letter on
EDGAR under the form type label CORRESP. Please understand that we
may have additional comments after reviewing your amendment and
responses to our comments.

      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 Vanessa Robertson at (202) 551-3649 or James
Atkinson at (202) 551-3674 if you have questions regarding
comments
on the financial statements and related matters.  Please contact
Sonia Barros at (202) 551-3655 or John Krug at (202) 551-3862 with
any other questions.

								Sincerely,

								Jeffrey P. Riedler
								Assistant Director

cc: 	Diane J. Harrison, Esquire
      6860 Gulfport Blvd. South No. 162
      S. Pasadena, FL 33707

Mr. Charles Godels
April 3, 2006
Page 1

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