SecProbe.io

April 4, 2012
 Via E-mail

Shelly Guidarelli President   Norman Cay Development, Inc. 4472 Winding Lane Stevensville, MI 49127
Re: Norman Cay Development, Inc.
 Form 10-Q for the quarter ended January 31, 2012  Filed March 14, 2012   Form 8-K dated January 23, 2012  Filed January 30, 2012  Response letter dated March 5, 2012
File No. 333-167284

Dear Ms. Guidarelli:
 We have reviewed your filing and respons e letter dated March 5, 2012 and have the
following comments.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to our comments, we ma y have additional comments.
 Form 8-K filed on January 30, 2012

 Form 8-K/A dated October 14, 2011, in corporated therein by reference

 1. According to the last paragraph of page 2, you acquired 100% of the shares of Discovery
Gold Ghana Limited on September 2, 2011.   Tell us about your consideration of whether Rule 8-04 of Regulation S-X required you to furnish financial statements and any pro
forma information specified by Rule 8-05 of Regulation S-X.

Shelly Guidarelli Norman Cay Development, Inc.  April 4, 2012 Page 2

 Item 1.  Business

 2. Please provide disclosure with respect to all material relationships that existed between
Norman Cay Development, Inc. and its aff iliates, on the one hand, and Discovery Gold
Ghana Limited and its affiliates, on the other hand, at the time of share exchange agreement.  Refer to Item 2.01(c) and (d) of Fo rm 8-K.  If no such relationships existed,
explain how the parties were introduced and decided to proceed with the transaction.
Identify any third parties that played a mate rial role in arranging or facilitating the
transactions.  Finally, identify any promoter s as required by Item 404(c) of Regulation S-
K.
 3. Please discuss the January 25, 2012 earn-in ag reement between North Springs Resources
Corp. and Discovery Gold Ghana Limited.  Provide  disclosure with respect to all material
relationships that existed between Norman Cay Development, Inc. and its affiliates,
Discovery Gold Ghana Limited and its affiliates, and North Springs Resources Corp. and its affiliates at the time of th e earn-in agreement.  If no such  relationships existed, explain
how the parties were introduced and decided to  proceed with the transaction.  Identify
any third parties that played a material role in arranging or facilita ting the transaction.
 4. We note your references on pages 4 and 5 to the Prospecting License, Adom Option
Agreement, and Option Assignment Agreement.  Please file these agreements as material
contracts.
 5. Please discuss why the transaction for the assign ment of the option to acquire all rights to
the prospecting license held by Adom Mining Ltd. was structured in  two transactions:
(1) the August 27, 2011 assignment of the opti on from Xtra-Gold Exploration Limited to
Discovery Gold Ghana Limited (“DGG”) for $250,000 and 5.71% of the common stock of DGG; and (2) the September 2, 2011 acquisition of DGG by Norman Cay
Development, Inc. for $100,000 and 17.5 millio n shares of Norman Cay Development
common stock.  In your discussion, address whether the option and the prospecting
license must held by a company organized in Ghana.
 6. Disclose whether the govern ment of Ghana consented to the assignment from Adom
Mining Ltd. to Discovery Gold Ghana of the opt ion to acquire rights  to the prospecting
license covering the Edum Banso Concession.  We note the following disclosure on page
4:  “Under the License, Adom had the right to (i) assign or mortgage its interest in the
License, subject to obtaining the consent of the Government of Ghana who may impose
certain conditions in connection therewith…”    Identify the government entity that
consented to the assignment of the option and the date of cons ent.  File the consent as a
material contract.  Also di sclose whether the acquisition of Discovery Gold Ghana by
Norman Cay Development (and thus the acq uisition of the assigned option by a U.S.
company) needed government consent.

Shelly Guidarelli Norman Cay Development, Inc.  April 4, 2012 Page 3

 7. Please clarify throughout your disclosure that DGG holds an option to acquire the rights
to Adom Mining’s license to prospect
 the Edum Banso Concessi on, but not the rights to a
license to mine or participate in mining  the property.  Disclose, if true, that Adom Mining
does not have a license to mine or participat e in the mining of the property.  Explain the
distinction and its impact on the ability to  develop and mine the property.  Disclose
whether and how DGG could obtain a license to mine the property.
 8. We note from your disclosure in  the first paragraph on page 4 that there is a gap in the
extension of Adom Mining’s prospecting license from July 20, 2008 to July 21, 2011,
when the government of Ghana extended the li cense to July 20, 2013.  Please disclose the
status of the prospecting li cense to the Edum Banso C oncession during this period.
 Government Regulation, page 20

 9. Please expand this section to discuss in mo re detail the laws and regulations by the
government of Ghana and any local authoritie s that govern and impact your ability to
explore and develop the Edum Banso Conce ssion.  In this regard, we note numerous
references to significant government regula tions in your risk factor disclosure.
 Item 5.  Directors and Executive Officers, page 30

10. You disclose in the Form 8-K filed on Nove mber 4, 2011, that Dean Huge was appointed
as the company’s Chief Financial Officer.  Please provide information regarding Dean
Huge required by Form 10, including the di sclosure under Items 401, 402, 403 and 404 of
Regulation S-K.
 Form 10-Q for the quarter ended January 31, 2012

 Financial Statements

 2. Summary of Significant Accounting Policies

 h) Mineral Property Costs, page 9

 11. It is unclear to us to what extent your capit alized carrying cost fo r your interest in the
Prospecting License between the governme nt of the Republic of Ghana and Adom
Mining Limited was recoverable at each bala nce sheet date.  Please advise and tell us
your consideration of the recoverability of th e carrying value of th is asset on October 31,
2011 and January 31, 2012.
 3. Acquisition of Discovery Gold Ghana Ltd.

 12. We note that your interest in the Prospec ting License between th e government of the
Republic of Ghana and Adom Mining Limited was conveyed between third parties in an

Shelly Guidarelli Norman Cay Development, Inc.  April 4, 2012 Page 4

 arm’s-length transaction primarily fo r cash on August 27, 2011.  Tell us your
consideration of whether th is August 27, 2011 transaction provides a more readily
determinable evidence of the fair valu e of the prospecting license you acquired on
September 2, 2011.  Tell us in this regard wh at, if any, carrying value Discovery Gold
Ghana Limited, (DGG) allocated to this pr ospecting license and how such a carrying
value was determined, prior to your acquisition of DGG on September 2, 2011.
 4. Mineral property

 Edum Banso property, page 10

 13. We note that Item 1.1 of the Earn-in Agreem ent filed as Exhibit 10.1 to your Form 8-K
filed on January 27, 2012 provides that Nort h Springs Resources Corp. will acquire a
10% “Working Interest in DGG’s Intere st” upon full payment of the $250,000 Initial
Payment, which was made in February 2012.  We further note from the table on page 10
that the carrying value of the Edum Banso Property was reduced by the deposit portion of
the Initial Payment, which was remitted in  January 2012.  Tell us how you plan to
account for full Initial Payment received by you in February 2012 and for the related
conveyance of the original 10% interest to North Springs Res ources.  Tell us whether this
assignment of a working interest to North Sp rings Resources is subject to prior approval
of the Government of Ghana under the provisions of the Pros pecting License between the
government of the Republic of Ghana and Adom Mining Limited.
 9. Subsequent Events, page 12

 14. According to your press release dated Febr uary 14, 2012 (filed as  exhibit 99.1 to your
Form 8-K filed on February 14, 2012) you rece ived 10,000,000 restricted shares of North
Springs Resources Corp. common stock in cons ideration for a 25% in terest in the Edum
Banso with a “current market valuation of th ese shares is in excess of $6.5 million.”  We
note that as of October 31, 2011 North Spri ngs Resources Corp. reported no revenues
since inception and that it re ported total assets of $60,589 a nd shareholders’ deficit of
$48,181.  Tell us how you plan to account for this  transaction.  Tell us the value at which
you intend to book these 10,000,000 North Springs Resources common shares.  Address the terms of the Earn-in Ag reement filed as Exhibit 10.1 to your form 8-K filed on
January 27, 2012, and explain for us in par ticular how you plan to account for the
provisions in Section 2.1 of that agreement which allows DGG to call back the 25% Working Interest in exchange for the 10,000,000 North Springs Resource common
shares.
 Item 2.  Management’s Discussion and Analysis of Financial Condition a nd Plan of Operation,
page 13
 15. Please provide a detailed and quantified discussion of your plan of operation.

Shelly Guidarelli Norman Cay Development, Inc.  April 4, 2012 Page 5

 Liquidity and Capital Resources, page 14

 16. Discuss the impact on the company’s liquidity  and capital resources  of the consulting
contracts that the company has recently entered into.  Disc uss how the company plans to
meet its cash obligations  under the contracts.
 17. Please discuss the company’s reliance on rela ted party loans and whether the company
will continue to rely on related party loans to meet its cash needs.

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.
 In responding to our comments, please provi de 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 Joseph Kemp f, Staff Accountant, at 202 -551-3352 or Carlos Pacho,
Senior Assistant Chief Accountant, at 202-551-38 10, if you have questions regarding comments
on the financial statements and related matters.  You may contact Ajay Kodur i, Staff Attorney, at
202-551-3310; Kathleen 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