ARK DEVELOPMENT, INC.
4225 New Forrest Drive
Plano, Texas 75093
February 15, 2008
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attn: H. Roger Schwall – Assistant Director
Laura Nicholson – Staff Attorney
Re: Ark Development, Inc.
Registration Statement on Form SB-2
Filed January 10, 2008
File Number 333-148574
Ladies and Gentlemen:
The following responses address the comments of the reviewing Staff of the Commission as set forth in a comment letter dated January 29, 2008 (the "Comment Letter") relating to the Registration Statement on Form SB-2 (the "Registration Statement") of Ark Development, Inc. (the "Company"). The answers set forth herein refer to each of the Staffs' comments by number.
General
1.
Please note that amendments to Regulation S-K will become effective February 4, 2008 and that Form SB-2 will be eliminated as of that date. With your next amendment, please amend your registration statement to comply with the new rules. Refer to Release 33-8876 (December 19, 2007) and the “Compliance Date” section.
Response
The Company acknowledges the Staff’s comment and has revised the registration statement in accordance with the Staff’s comments.
2.
Please provide a reasonably detailed table of contents. See Item 502 of Regulation S-B.
Response
The Company acknowledges the Staff’s comment and has revised the registration statement in accordance with the Staff’s comments.
Management, page 24
Directors and Executive Officers, page 24
3.
Please describe in more detail Noah Clark’s business experience during the past five years. See Item 401(a)(4) of Regulation S-B.
Response
The Company acknowledges the Staff’s comment and has revised the registration statement in accordance with the Staff’s comments.
We hereby acknowledge the following:
·
should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
·
the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
·
the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
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We appreciate your timely consideration of these matters in your review of the filing referenced above. Thank you in advance for your prompt review and assistance.
Very truly yours,
___/s/ Noah Clark_________
Noah Clark
Chief Executive Officer & President