February 5, 2019

Paul Adler
President and Chief Financial Officer
Global Diversified Marketing Group Inc.
4042 Austin Boulevard, Suite B
Island Park, New York 11558

       Re: Global Diversified Marketing Group Inc.
           Registration Statement on Form S-1
           Filed December 7, 2018
           File No. 333-228706

Dear Mr. Adler:

       We have reviewed your registration statement and have the following
comments. In
some of our comments, we may ask you to provide us with information so we may
better
understand your disclosure.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Form S-1 filed December 7, 2018

The Company, page 3

1.     We note the company maintains five trademarked brands. Please disclose
the duration of
       the trademarks pursuant to Item 101(h)(4)(vii) of Regulation S-K.
2.     We note your disclosure that you have "a direct distribution
relationship with several
       Fortune 500 companies." Please expand your disclosure to discuss the
nature of your
       relationship and whether you have any agreements in place with these
companies.
Dilution, page 8

3.     Please revise your disclosure to include your calculation of dilution
from this offering
       pursuant to Item 506 of Regulation S-K.
 Paul Adler
FirstName LastNamePaul Adler
Global Diversified Marketing Group Inc.
Comapany NameGlobal Diversified Marketing Group Inc.
February 5, 2019
February 5, 2019 Page 2
Page 2
FirstName LastName
Competition, page 12

4.       Please revise the disclosure to identify the sources of the industry
data where applicable.
         For example, we note your statements regarding the growth of the
snacking business to
         "US$3.4 billion globally in 2017" and the compounded annual growth
rate of 10% for the
         "snackable fruit and vegetable category" on page 12, and also your
statements regarding
         "young snackers" on page 13.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
17

5.       You disclose that Paul Adler entered into an agreement with Tiber
Creek Corporation for
         the preparation and filing of this registration statement. You later
disclose on page 22 that
         James Cassidy, your former officer and president of Tiber Creek
Corporation, provided
         services to the company without charge including preparation and
filing of the corporate
         charter documents and this registration statement. Please file any
agreement with Tiber
         Creek Corporation, or alternatively explain why you believe such
agreement is not
         required to be filed. See Item 601(b)(10) of Regulation S-K.
Advisors, page 20

6.       We note your disclosure regarding the Company's team of advisors.
Please disclose
         whether there are any compensatory arrangements with the advisors.
Executive Compensation, page 21

7.       Please provide the summary compensation table as required by Item
402(n) of Regulation
         S-K.
Certain Relationships and Related Transactions, page 22

8.       We note you disclose in Note 4 on page F-9 in the notes to your
unaudited interim
         financial statements that during the year ended December 31, 2017 and
nine months ended
         September 30, 2018, you incurred consulting fees of $37,500 and
$127,500, respectively,
         related to services provided by a shareholder. In this regard, please
revise your disclosure
         here to comply with the requirements of Item 404(d) of Regulation S-K.
Signatures, page 29

9.       In addition to Paul Adler signing in his capacity as a director,
please also revise to have
         Mr. Adler sign the registration statement in his individual capacity
as your principal
         executive officer, principal financial officer, and controller or
principal accounting officer.
         See Instruction 1 to the Signatures section of Form S-1.
 Paul Adler
FirstName LastNamePaul Adler
Global Diversified Marketing Group Inc.
Comapany NameGlobal Diversified Marketing Group Inc.
February 5, 2019
Page 3
February 5, 2019 Page 3
FirstName LastName
General
Financial Statements, page F-1

10.      As you prepare your amended document, please refer to the requirements
set forth in Rule
         8-08 of Regulation S-X regarding the age of the financial statements
included in the filing
         and update your financial statements and related financial information
accordingly.


11.      We note within the document you state that you effected the
acquisition of Global
         Diversified Holdings, Inc. (GDHI) through the exchange of 200 shares
of common stock
         for all the shares in GDHI. Please include disclosure within the
document which explains
         how you accounted for this transaction. As both entities are under
common control, it
         appears the transaction would not meet the definition of a business
combination. Rather,
         it appears the transaction should be accounted for as a combination of
entities under
         common control as required by FASB ASC 805-50-05-5, and your financial
statements
         should be prepared in accordance with the guidance set forth in FASB
ASC 805-50-45-2
         through 45-5, such that you should present combined financial
statements for both entities
         for all periods during which they were under common control.
Global Diversified Holdings, Inc. Financial Statements
Statements of Cash Flows, page F-6

12.      Please revise your Statements of Cash Flows to present the cash
payments to redeem
         common stock as a cash flow from financing activities, or explain to
us why you believe it
         is appropriately classified as a cash flow from investing activities.
This comment also
         applies to the Statements of Cash Flows for the fiscal years ended
December 31, 2017 and
         2016. Refer to FASB ASC 230-10-45-15 for additional guidance.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
 Paul Adler
Global Diversified Marketing Group Inc.
February 5, 2019
Page 4

       You may contact Lily Dang, Staff Accountant, at (202) 551-3867 or
Jenifer Gallagher,
Staff Accountant, at (202) 551-3706 if you have questions regarding comments on
the financial
statements and related matters. Please contact Anuja A. Majmudar,
Attorney-Advisor, at (202)
551-3844 or, in her absence, Kevin Dougherty, Attorney-Advisor, at (202)
551-3271 with any
other questions.



FirstName LastNamePaul Adler                         Sincerely,
Comapany NameGlobal Diversified Marketing Group Inc.
                                                     Division of Corporation
Finance
February 5, 2019 Page 4                              Office of Natural
Resources
FirstName LastName