ASHTON WOODS USA LLC
                            1080 Holcomb Bridge Road
                             Building 200, Suite 350
                             Roswell, Georgia 30076


March 3, 2006

VIA EDGAR
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Andrew Schoeffler

         Re:      Ashton Woods USA LLC -- Registration Statement on Form S-4
                  (File No. 333-129906) (the "filing")

Ladies and Gentlemen:

                  The Company hereby acknowledges that:

         -        should the Commission or the staff, acting pursuant to
                  delegated authority, declare the filing effective, it does not
                  foreclose the Commission from taking 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.

         It would be appreciated if, as soon as the filing has become effective,
you would so inform Elizabeth Noe by telephone at (404) 815-2287 or Jay
Rodriguez at (404) 815-2283.

                                         Very truly yours,

                                         ASHTON WOODS USA LLC



                                         By: /s/ Robert Salomon
                                             ----------------------------------
                                             Robert Salomon
                                             Chief Financial Officer