PARSONS LAW FIRM
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James B. Parsons* &nb sp; *Also admitted in Oregon and
jparsons@parsonslaw.biz &nb sp; the Northern Mariana Islands
VIA EDGAR CORRESPONDENCE AND REGULAR MAIL
December 20, 2005
Ms. Cicely Luckey,
Branch Chief
Ms. Yolanda Crittendon,
Staff Accountant
Division of Corporate Finance
United States Securities and Exchange Commission
Washington, D.C. 20549
Mail Stop 4561
Re: Commerce Development Corporation Ltd.
Form 10-KSB for the year ending December 31, 2004
Form 10-QSB for the quarters ending March 31, 2005, June 30, 2005 and
September 30, 2005
File #333-104647
Dear Ms. Luckey and Ms. Crittendon:
We represent Commerce Development Corporation Limited (the "Company") regarding certain securities matters. The Company has received your letter dated November 30, 2005, with comments regarding certain periodic reports filed on behalf of the Company.
On behalf of the Company, we would like to request an extension to answer the comments set forth in the November 30, 2005 letter. We would request an extension to answer until December 28, 2005.
On behalf of the Company, we would appreciate your consideration in reviewing this request.
Very truly yours.
PARSONS LAW FIRM
/s. James B. Parsons
JAMES PARSONS
JBP:kpc
cc: Andrew Mercer