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SEC Response Letter    Norman Cay Development, Inc.

 4472 Winding Lane, Stevensville, MI 49127 tel: 269-429-7002

 September 2, 2010

 Kathleen Krebs

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street N.E.

 Washington DC 20549

 Re:

 Norman Cay Development Inc.

 File No. 333-167284

 SEC Comment letter dated August 18, 2010

 Dear Ms. Krebs:

 Norman Cay Development Inc. (the “Company”), a Nevada corporation, has received and reviewed your letter of August 18, 2010, pertaining to the Company’s Registration Statement on Form S-1 (the “Filing”) as filed with the Securities & Exchange Commission (the “Commission”) on June 3, 2010.

 Specific to your comments, our responses below are in addition to those filed via the Edgar system:

 FORM S-1

 The Following numbered responses correspond to those numbered comments as set forth in the comment letter dated August 18, 2010.

 Prospectus Summary. page 6

 The Company Overview, page 6

 1.

 We note your response to comment three from our letter dated July 30, 2010. Please

 revise to indicate clearly whether you have filed an application to become a reseller for any wireless provider and have performed any market research to determine a suitable retail location. Further, revise to disclose whether you have received any firm commitments or indications of interest from friends, family, or business acquaintances regarding potential investments in your company.

 RESPONSE:

 We have revised the Filing on Pages 6-7 to include the following language:

 Pg. 6:

 “Norman Cay Development, Inc. was incorporated in the State of Nevada on April 28, 2010. We intend to become an authorized reseller of wireless telephones and service plans. As of the date hereof, we have not filed any application to become an authorized reseller with any wireless network distributors. The Company has contacted locations where space, both retail and kiosk, is available. Due to the current financial conditions in the area, retail space is being offered with many incentives. We do not foresee any significant difficulties in identifying and securing adequate retail space.”

  Pg. 7:

 “Although we were only recently incorporated and have not yet commenced substantive operations, we believe that conducting this offering will allow the Company added flexibility to raise capital in today's financial climate. Although, there can be no assurance that we will be successful in our attempt to sell 100% of the shares being registered hereunder, we believe that investors in today's markets demand full transparency and by our registering this offering we will be able to capitalize on this fact. The Company intends to begin substantive operations in the coming months and believes it will be able to do so even if no funds are raised hereunder. Our initial plan of operations calls for the Company to finalize the application process with several wireless providers. This requires the Company to show initial capital in the range of $20,000-$25,000, this amount will be available to us if we are able to sell 50% of the shares offered hereby. If we receive the funds necessary to become an authorized reseller for one or more wireless service providers, we will execute such agreement and begin seeking out adequate kiosk space from which we can begin our operations. Initially, we intend to use proceeds from this offering to secure the reseller’s license, identify and secure the retail location, and purchase initial inventory.  In the absence of such sales, our Management will seek out reasonable loans from friends, family and business acquaintances necessary to allow the Company to continue to meet its obligations, including covering any such cost associated with being a fully reporting Company with the Securities and Exchange Commission ("SEC") and continuing to develop our initial business operation. At this point we have not received any firm commitments or indications from any family, friends or business acquaintances regarding any potential investment in the Company.”

 2.

 We note your response to comment four from our letter dated July 30, 2010. Revise the second to last sentence in the first paragraph at the top of page 7 to clearly state the company, Ms. Guidarelli, or any other affiliated or unaffiliated party has no plans to use the company as a vehicle for a private company to become a reporting company once the company becomes a reporting company.

 RESPONSE:

 We have revised the Filing on Page 7 to include the following language:

 “Neither the Company, Ms. Guiardelli nor any other affiliated or unaffiliated entity has any plans to use the Company as a vehicle for a private company to become a reporting company once Norman Cay Development, Inc. becomes a reporting Company.”

 Risk Factors, page 8

 Shares of our common stock that have not been registered under the Securities Act of 1933, as amended. regardless of whether such shares are restricted or unrestricted. are subject to resale restrictions imposed by Rule 144. including those set forth in Rule 144(i) which apply to a "shell company" .... page 9

 3.

 Please revise the second sentence of this risk factor heading and the last sentence of the risk factor to clarify that any shares held by affiliates, including any shares received in a registered offering, will be subject to the resale restrictions of Rule 144(i).

 RESPONSE:

 We have revised the Filing on Page 10 to include the following language:

 “Shares of our Common Stock that have not been registered under the Securities Act of 1933, as amended, regardless of whether such shares are restricted or unrestricted, are subject to resale restrictions imposed by Rule 144, including those set forth in Rule 144(i) which apply to a “shell company.” In addition, any shares of our Common Stock that are held by affiliates, including any received in a registered offering, will be subject to the resale restrictions of Rule 144(i).

 2

  Pursuant to Rule 144 of the Securities Act of 1933, as amended (“Rule 144”), a “shell company” is defined as a company that has no or nominal operations; and, either no or nominal assets; assets consisting solely of cash and cash equivalents; or assets consisting of any amount of cash and cash equivalents and nominal other assets.  As such, we are a “shell company” pursuant to Rule 144, and as such, sales of our securities pursuant to Rule 144 are not able to be made until 1) we have ceased to be a “shell company"; 2) we are subject to Section 13 or 15(d) of the Securities Exchange Act of 1934, as amended; 3)and have filed all of our required periodic reports for at least the previous one year period prior to any sale pursuant to Rule 144; and a period of at least twelve months has elapsed from the date “Form 10 information” has been filed with the Commission reflecting the Company’s status as a non-“shell company.”  If less than 12 months has elapsed since the Company ceases being a “shell company”, then only registered securities can be sold pursuant to Rule 144. Therefore, any restricted securities we sell in the future or issue to consultants or employees, in consideration for services rendered or for any other purpose will have no liquidity until and unless such securities are registered with the Commission and/or until a year after we cease to be a “shell company” and have complied with the other requirements of Rule 144, as described above.  As a result, it may be harder for us to fund our operations and pay our consultants with our securities instead of cash.  Furthermore, it will be harder for us to raise funding through the sale of debt or equity securities unless we agree to register such securities with the Commission, which could cause us to expend additional resources in the future.  Our status as a “shell company” could prevent us from raising additional funds, engaging consultants, and using our securities to pay for any acquisitions (although none are currently planned), which could cause the value of our securities, if any, to decline in value or become worthless. Lastly, any shares held by affiliates, including shares received in any registered offering, will be subject to the resale restrictions of Rule 144(i).”

 Because our sole officer and director owns an aggregate of 100% of our outstanding common stock. the market price of our shares would most likely decline if he were to sell a substantial number of shares all at once or in large blocks, page 9

 4.

 Please revise the third sentence of this risk factor to disclose that Ms. Guidarelli will be subject to the resale restrictions of Rule 144(i) for the resale of her shares.

 RESPONSE:

 We have revised the Filing on Page 10 to include the following language:

 “Because our sole officer and director owns an aggregate of 100% of our outstanding Common Stock, the market price of our shares would most likely decline if she were to sell a substantial number of shares all at once or in large blocks.

 Our sole officer and director, Shelley Guidarelli, owns 5,000,000 shares of our Common Stock, which equates to 100% of our outstanding Common Stock prior to the completion of this offering.  There is presently no public market for our Common Stock, although we plan to apply for quotation of our Common Stock on the FINRA over-the-counter bulletin board upon the effectiveness of the registration statement of which this prospectus forms a part.  Any shares held by Ms. Guidarelli, including shares received in any registered offering, will be subject to the resale restrictions of Rule 144(i).  The offer or sale of a large number of shares at any price may cause the market price to fall.  Sales of substantial amounts of Common Stock or the perception that such transactions could occur may materially and adversely affect prevailing markets prices for our Common Stock.”

 If a Market for Our Common Stock Does Not Develop, ... page 13

 5.

 Please revise this risk factor to remove the double negatives. The relevant part of the first sentence should read "and no such market may ever develop," and the relevant part of the third sentence should read "There is no guarantee that our shares may be traded."

 RESPONSE:

 We have revised the Filing on Page 14 to include the following language:

 “If a Market for Our Common Stock Does Not Develop, Shareholders May Be Unable To Sell Their Shares.

 There is currently no public trading market for our Common Stock, and no such market may ever develop. While we intend to contact an authorized OTC Bulletin Board market-maker for sponsorship of our securities on the OTC Bulletin Board, there is no assurance that our application will be approved. There is no guarantee that our shares may ever be traded on the bulletin board, or, if traded, a public market may not materialize. If our Common Stock is not traded on the bulletin board or if a public market for our Common Stock does not develop, investors may not be able to re-sell the shares of our Common Stock that they have purchased and may lose all of their investment.”

 3

  Use of Proceeds, page 14

 6.

 You provide tabular disclosure of how you intend to use the net proceeds of the offering assuming that you sell all the shares. Provide similar tabular disclosure of your intended use of the net offering proceeds if you sell only 50% and 10% of the shares being offered. This will facilitate a reader's understanding and comparison of the potential outcomes of the offering.

 RESPONSE:

 We have revised the Filing on Page 15 to include a chart of our intended use of the net offering proceeds if we only sold 50% and 10% of the shares being offered.

 7.

 Please further itemize the amount of proceeds that you intend to use for each purpose under "Business Development."

 RESPONSE:

 We have revised the Filing on Page 15 to include a chart which further itemizes the amount of proceeds we intend to use for each purpose under “Business Development.”

 Information with respect to the Registrant, page 18

 8.

 Please remove the reference to National Intelligence Association, Inc. or explain this reference.

 RESPONSE:

 This was a typographical error and we have removed this reference on Page 19 of the Filing.

 Description of our Business. page 18

 9.

 We note your statement in the fifth paragraph on page 18 that you have "begun taking the necessary steps to complete the applications to become a licensed reseller." As discussed in comment one above, revise to disclose whether you have filed any application with a wireless company and, if so, where you are in the application process. Also, to inform your potential investors, please describe the major milestones of the application and review process.

 RESPONSE:

 We have revised the Filing on Page 20-21 to include the following language:

 Pg. 20:

 “We have not applied for a reseller's license and although we have not obtained any reseller’s license, to date, we plan to seek out and establish mutually beneficial relationships with various wireless wholesalers through which we will act as an authorized reseller.”

 Pg. 21:

 “Obtaining a Resellers License

 In the current marketplace, the most common and easiest way of becoming a licensed reseller is by contacting a master dealer.  The master dealer will typically have a contract with a major carrier (i.e. Verizon, Cricket, Sprint, AT&T) that will authorize the master dealer to establish and maintain reseller's licenses with local and regional retailers. The master dealer will operate as the conduit to the major supplier or to major suppliers; some have only one cell phone carrier that they represent and others may represent multiple carriers.

 The process of identifying and contracting with a master dealer is not always an easy task, and may require proof of adequate capitalization and a solid business plan prior to contracting with any potential reseller.  Once licensed, the master dealer will typically provide basic training and support; they may provide collateral items necessary to launch our retail efforts (posters, brochures, paper contracts) and they will act as the supplier for our cell phone inventory. Additionally, the master dealer will provide the activation system for new service activation and typically they will be responsible for paying commissions to us for the new activations.

 Once under contract, the sale of a variety of licensed products will be a key element of our strategy and we intend to expand our offerings of licensed products over the coming years. Under typical license agreements with any master dealer, we will be generally required to achieve minimum net sales of licensed products, pay guaranteed minimum royalties, and make specified royalty and advertising payments (usually based on a percentage of net sales of licensed products).  Failure to satisfy the requirements or otherwise meet our obligations under a potential license agreement usually grants the licensor the right to terminate our license. Once we obtain a reseller’s license, we will file this agreement as an exhibit to this S-1 Registration Statement.”

 4

 10.

 Further, other than an initial capital requirement of $20,000 to $25,000, please disclose whether there are any other material conditions or limitations to becoming a licensed reseller such as franchised territory. Once you obtain a reseller's license, please confirm you will file this agreement as an exhibit.

 RESPONSE:

 We have revised the Filing on Page 21 to include the following language:

 “The process of identifying and contracting with a master dealer is not always an easy task, and may require proof of adequate capitalization and a solid business plan prior to contracting with any potential reseller.  Once licensed, the master dealer will typically provide basic training and support; they may provide collateral items necessary to launch our retail efforts (posters, brochures, paper contract