SecProbe.io

November 4, 2011
 Via E-mail

Shelly Guidarelli President   Norman Cay Development, Inc. 4472 Winding Lane Stevensville, MI 49127
Re: Norman Cay Development, Inc.
 Form 8-K
Filed October 17, 2011 File No. 333-167284

Dear Ms. Guidarelli:
 We have reviewed your filing and have the following comment.  Please respond to this
letter within ten business days by amending your  filing, by providing the requested information,
or by advising us by when you will provide the re quested response.  If you do not believe our
comment applies 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 filing and the information you provide in
response to this comment, we may have additional comments.

General

1. We note your disclosure under Item 5.06 that  management has determined the company
is no longer a shell corporation as defined in Rule 405 of the Securities Act or Rule 12b-2
of the Securities Exchange Act.  Under that  definition, a shell company has no or nominal
operations and either (i) no or nominal assets , (ii) assets consisti ng solely of cash and
cash equivalents, or (iii) asse ts consisting of any amount of  cash and cash equivalents and
nominal other assets.  By referring to specific parts of your disclosure  or business, please
tell us how you factually fall outside the de finition of a shell company.  Currently we
note you have no operations (see page 27 wh ich states you have no operating revenues)
and all of your assets consis t of cash (see also page 27).  In the alternative, amend your
Form 8-K to indicate you conti nue to be a shell company.
 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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.

Shelly Guidarelli Norman Cay Development, Inc.  November 4, 2011 Page 2

 In responding to our comment, please provide a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of  the United States.

You may contact Ajay Koduri, Staff Attorne y, at 202-551-3310; Kathl een Krebs, Special
Counsel, at 202-551-3350; or me at 202-551-3810 with any other questions.

Sincerely,
   /s/ Kathleen Krebs for   Larry Spirgel
Assistant Director
 cc: Via E-mail

 Wade Huettel, Esq.
 Carrillo Huettel, LLP