United States securities and exchange commission logo December 23, 2021 John Norman Chief Executive Officer Evolution Development Group, Inc. 10949 Esteban Drive Ft. Myers, FL 33912 Re: Evolution Development Group, Inc. Post-Qualification Amendment No. 1 to Offering Statement on Form 1-A Filed December 20, 2021 File No. 024-11127 Dear Mr. Norman: This is to advise you that we do not intend to review your amendment. We will consider qualifying your offering statement at your request. If a participant in your offering is required to clear its compensation arrangements with FINRA, please have FINRA advise us that it has no objections to the compensation arrangements prior to qualification. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Brian Fetterolf at 202-551-6613 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Kendall Almerico