SecProbe.io

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Mail Stop 6010	April 12, 2006

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

Re:	Avalon Development Enterprises, Inc.
	Amendment No. 4 to Registration Statement on Form SB-2,
		filed April 6, 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.

Risk Factors

(5) Our Competitors Have Greater Financial Resources than We Do .
. .
. Page 3

1. We note your response to our prior comment 4 and reissue that
comment.  You discussion of Mr. Godels` experience of commercial
building leasing should appear in the business section of the
prospectus not in this risk factor regarding competition.  The
discussion of this information in the business section should
explain
the meaning of "triple net leases" and how the planning and
development of these leases has provided him with experience
relevant
to your business plan.

Business

2. We note your response to our prior comment 11 and reissue that
comment.  Please revise your disclosure to explain in
chronological
order when your office was at 770 1st Avenue and when you moved to
5113 Central Avenue and who owned and leased the relevant space to
you at such times.

3. We note your response to our prior comment 12 and reissue that
comment.  You have revised your disclosure to indicate that your
President "assists in" financial strategies instead of
"customizing"
them.  It appears that this re-characterization does not change
the
nature of the experience of your President that you are relying on
to
implement your business plan.  You should still provide a robust
discussion of how your President assists in these financial
strategies for clients through the use of real estate.

4. We note your response to our prior comment 13 and reissue that
comment.  It is still unclear what you mean by the statement,
"None
of his relationships could be considered to be private . . . ."

5. Please refer to the first paragraph on page 19.  You state you
"are building upon our President`s successes."  In the last
sentence
of this paragraph you state "he is also experienced at commercial
property acquisition for long term gain through leasing and
appreciated value."  Please clarify whether this experience is a
result of his acquisition and leasing of commercial property for
his
personal gain or vicarious experience as an accountant for
individuals and entities that actually acquired and leased the
properties.  Clarify the extent to which he was involved in the
acquisition and leasing of these commercial properties.

Financial Statements - December 31, 2005

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

6. We note your response to comment 16 and the changes that you
have
made to the financial statements.  In addition to those changes,
please make the following revisions to your disclosure:

* the earnings (loss) per common share amounts shown in the income
statements for 2005, 2004 and 2003 need to be revised in order to
agree to the amounts disclosed in each respective earnings per
common
share note;

* the line items disclosed in the 2005 statement of changes in
stockholder`s equity for the beginning balance and issuance of
common
stock need to be revised to reflect the stock split.  The separate
line item for the stock split should be removed similar to the
presentations for the other periods presented;

* the line item disclosed in the 2004 statement of changes in
stockholder`s equity for the restatement should be removed since
the
effect of the restatements is already reflected in the beginning
balance and issuance of common stock line items; and

* the last sentence of Note G for 2004 should be revised to state
that the calculations have been restated.

Financial Statements - December 31, 2004

Note F - Fixed Asset Dispositions, page F-15

7. We note your response to comment 17.  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 in
your notes.

*	*	*	*	*

      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 12, 2006
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