SecProbe.io

September 10, 2010

Via U.S. Mail
 Shelley Guidarelli President and Chief Executive Officer
Norman Cay Development Inc.
4472 Winding Lane Stevensville, MI 49127
Re: Norman Cay Development Inc.
Amendment No. 3 to Form S-1 Filed September 3, 2010
  File No. 333-167284
 Dear Ms. Guidarelli:

We have reviewed your registration statem ent and have the following comments.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.
 Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe  our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
 After reviewing any amendment to your re gistration statement and the information you
provide in response to these comments, we may have additional comments.

Prospectus Summary, page 6

The Company Overview, page 6

1. We note your response to comment one from our letter dated August 18, 2010.  We also
note from the bottom of page 21 that you in tend to open locations in Stevensville,
Michigan.  Please revise the first paragraph to disclose the area where you intend to lease
retail space.

Shelley Guidarelli
Norman Cay Development Inc.
September 10, 2010 Page 2

Description of Our Business, page 20

First Year Operations, page 21

2. We note your statement at the bottom of page 21 that there is only one wireless reseller in
Stevensville and there is unta pped market potential in the ar ea.  Revise to disclose the
name of the competing reseller.  Also, explain why you believe there is untapped market potential in Stevensville.  In this regar d, we note Stevensville appears to have a
population of about 1,000 people (refer to  www.city-data.com/city/Stevensville-
Michigan.html) and Berrien County has a population of about 160,000 people (refer to
quickfacts.census.gov/qfd/states /26/26021.html).  Please account for these factors when
in your explanation.

The Industry, page 24

3. At the top of page 25, we note your disclo sure regarding the growth of cell phone
subscribers worldwide.  However, we note your market is Stevensville.  Please explain
how and why worldwide subscriber growth applies to your market.  Further, please
explain how Mr. Slim’s fortunes relate and ap ply to your operations.  In this regard, we
note he and his family control America Mov il whose operations are significantly larger
than yours.
 Management’s Discussion and Analysis, page 25

 Liquidity and Capital Resources, page 25

 4. We note your response to comment 16 from  our letter dated August 18, 2010, but we
partially re-issue this comment.  Please revise to explain how you intend to repay the
interest and principal on the note due to Mr . Ross and whether you will use any of the
proceeds from this offering to repay the note.

Directors, Executive Officers, Promoters and Control Persons, page 27

5. We partially reissue comment 19 from our  letter dated August 18, 2010.  Revise to
disclose Mr. Ross’s role in the company and explain whether he is a promoter under Rule
405 of Regulation S-K.  If applicable, please give us your reasons for concluding he is
not a promoter or provide the disclosure requ ired under Item 404(c) of Regulation S-K.
 Financial Statements, page F-1

 6. Please update your financial statements to in clude interim financial statements for the
three months ended July 31, 2010.

Shelley Guidarelli
Norman Cay Development Inc. September 10, 2010 Page 3

 You may contact Melissa Ha uber, Staff Accountant, at 202-551-3368 or Robert
Littlepage, Accountant Branch Chief, at  202-551-3361 if you have questions regarding
comments on the financial statements and relate d matters.  Please contact  Ajay Koduri, Staff
Attorney, at 202-551-3310 or Kathleen Krebs, Special Counsel, at 202-551-3350 with any other
questions.
Sincerely,
     /s/ Kathleen Krebs for
Larry Spirgel Assistant Director
cc: Via facsimile to 619-330-1888

 Wade D. Huettel, Esq.  Carrillo Huettel, LLP