SecProbe.io

October 14, 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. 4 to Form S-1 Filed October 14, 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.

Description of Business, page 20

First Year Operations, page 21

1. We note your response to comment two from our letter dated September 10, 2010.  We also note you have revised your disclosure to  discuss the proximity of larger and more
populous cities such as South Bend, Gr and Rapids, and Chicago that surround
Stevensville, Michigan and how your target customers may reside in those surrounding
areas which, in turn, creates enormous mark et potential for you.  However, since you now
consider South Bend, Grand Rapids, and Chi cago to contain target  customers, please
revise this section to discuss how your co mpetitors in those areas may affect your
operations.  In this regard, please discuss how larger, more established competitors may affect your business.  Also, revise the Co mpetition section to discuss the affects of
competing with cell phone st ores in these areas.

Shelley Guidarelli
Norman Cay Development Inc.
October 14, 2010 Page 2

 Management’s Discussion and Analysis, page 25

 Liquidity and Capital Resources, page 25

 2. We note your response to comment four fr om our letter dated September 10, 2010.
Please revise in the appropriate places (s uch as your Risk Fa ctor section and you
discussion under this section) to disclose what level of revenues you will need to generate to pay off the note.  In this regard, please ta ke into account your di sclosure in the second
to last paragraph on page 23 that you es timate the start-up cost s to be between $26,000
and $38,300.

Directors, Executive Officers, Promoters and Control Persons, page 28

3. We note your response to comment five from  our letter dated September 10, 2010.  Rule
405 states a promoter includes any person who, ac ting alone or in conjunction with one or
more other persons, directly or indirectly takes initiative  in founding and organizing the
business or enterprise of an issuer.  Please tell us why Mr. Ross ha s not indirectly taken
the initiative in founding and organizing your business.

In this regard, we note your response states that he has provided cap ital to finance the
start-up of your operations.  Mo re specifically, the disclosure at the bottom of page 25
states the note owed to Mr. Ross was used  to finance professional fees and general
operating costs, and the middle of page 26 states you spent $25,000 of the proceeds from
this note in the three months ended July 31, 2010 to pay for legal and accounting fees to register this offering.  Furthe r, we note, in the last para graph on page 15, the Use of
Proceeds disclosure states you will use the pro ceeds of this offering to facilitate the
development of your business including obtaini ng a wireless reseller’s license.  Please
address these facts in explai ning why Mr. Ross has not indir ectly taken the initiative in
founding and organizing your business.

Please contact Ajay Koduri, Staff Attorney, at 202-551-3310 or Kathleen Krebs, Special
Counsel, at 202-551-3350 with any questions.
Sincerely,
      /s/ Kathleen Krebs for
Larry Spirgel Assistant Director
cc: Via facsimile to 619-330-1888

 Wade D. Huettel, Esq.  Carrillo Huettel, LLP