SecProbe.io

February 24, 2012
 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 January 30, 2012 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 when you will provide the requested 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.    Item 5.06

1. We note you believe you are no longer a shell company because you have acquired 100%
of Adom Mining Company Limited’s interest in the Edum Banso area of the Western
Region of Ghana.  By referring to specific part s of your disclosure or business, please tell
us in detail how you factually fall outside th e definition of a shell company.  We note a
shell company has no or nominal operations and either (i) no or nominal assets, (ii) assets
consisting solely of cash and cash equivalents, or (iii) assets consis ting of any amount of
cash and cash equivalents and nominal other as sets.  In the alternative, amend your Form
8-K to indicate you continue 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.  February 24, 2012 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

 Luis Carrillo, Esq.  Carrillo Huettel, LLP