April 1, 2005



via U.S. mail

Mr. Dwight Foster
Chief Financial Officer
Murray United Development Corp.
P.O. Box 224
Landing, NJ 07850


	Re:	Murray United Development Corp.
		Form 10-KSB for the fiscal year ended July 31, 2004
		Form 10-QSB for the quarterly period ended January 31,
2005
		File No. 033-19048-NY


Dear Mr. Foster:

      We have reviewed the above filings and have the following
comments.  Our review has been limited to the areas identified
below.
Please provide us a response to the comments below and comply with
the comments in future filings .  If you disagree, we will
consider
your explanation as to why our comment is inapplicable or a
revision
is unnecessary.  Please be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.








10-KSB for the fiscal year ended July 31, 2004

Controls and Procedures, page 27

1. We note your disclosure that your "Chief Executive Officer and
[your] Chief Financial Officer concluded that the Company`s
disclosure controls and procedures are effective, in enabling the
Company to record, process, summarize and report information
required
to be included in the Company`s periodic SEC filings within the
required period of time." Revise to clarify, if true, that your
officers concluded that your disclosure controls and procedures
are
also effective to ensure that information required to be disclosed
in
the reports that you file or submit under the Exchange Act is
accumulated and communicated to your management, including your
chief
executive officer and chief financial officer, to allow timely
decisions regarding required disclosure.  See Rule 13a-15(e) and
Rule
15d-15(e) of the Exchange Act.

2. Rather than indicate there have been no significant changes in
your internal controls, disclose any change in your internal
control
over financial reporting identified in connection with the
evaluation
that occurred during your last fiscal quarter that has materially
affected, or is reasonably likely to materially affect your
internal
control over financial reporting as required by Item 308(c) of
Regulation SB.  Refer to Release 33-8238 for additional guidance
related to amendments to the disclosure requirements, which were
effective August 14, 2003.

Financial Statements, page F-1

3. Please note your financial statements should not be prepared on
your auditor`s letterhead as well as on the face of the financial
statements, you should not refer the reader to the auditor`s
report.
Please consider these items when you file your next Form 10-KSB.


Closing Comments

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your responses to our comments
and
provide any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your responses to our
comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to the company`s disclosure, they
are responsible for the accuracy and adequacy of the disclosures
they
have made.  In connection with responding to our comments, please
provide, in writing, a statement from the company acknowledging
that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* 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
federal securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.

      You may contact Jenifer Gallagher at (202) 942-1923 if you
have
any questions regarding the comments.  Direct questions relating
to
all other disclosure issues to the undersigned at (202) 942-1870.
Direct all correspondence to the following ZIP code: 20549-0405.



							Sincerely,



							H. Roger Schwall
							Assistant Director
??

??

??

??

Mr. Dwight Foster
Murray United Development Corp.
April 1, 2005
Page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE