May 29, 2019

Stavros Triant
Chief Executive Officer
Golden Developing Solutions, Inc.
4100 E Mississippi Ave, Suite 315
Denver, CO 80246

       Re: Golden Developing Solutions, Inc.
           Form 10-12G
           Filed May 1, 2019
           File No. 000-56051

Dear Mr. Triant:

       We have reviewed your filing 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 these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-12G

Introduction, page 2

1.    In an appropriate place in your Business discussion, please address
government approval
      of cannabis-related products. See Item 101(h)(4)(viii) and Item
101(h)(4)(ix) of
      Regulation S-K.
2.    Please disclose the number of your total employees and number of
full-time employees.
      Please see Item 101 (h)(xii) of Regulation S-K.
3.    You have disclosed in a risk factor on page 8 that one of the risks to
your business is the
      risk that you could lose "certain current strategic relationships." In an
appropriate place in
      your Business discussion, please discuss your current strategic
relationships.
4.    We note that you are voluntarily registering your common stock under
Section 12(g) of
      the Securities Exchange Act of 1934. Please note that your registration
statement will
      become effective by operation of law 60 days from the date you filed it
and that you will
 Stavros Triant
FirstName LastNameStavros Triant
Golden Developing Solutions, Inc.
Comapany NameGolden Developing Solutions, Inc.
May 29, 2019
May 29, 2019 Page 2
Page 2
FirstName LastName
         then be responsible for filing reports required by Section 13 of the
Securities Exchange
         Act of 1934. We also may continue to comment on your registration
statement after the
         effective date. If you do not wish to incur those obligations until
all of the following
         issues are resolved, you may wish to consider withdrawing your
registration statement and
         resubmitting a new registration statement when you have revised your
document. For
         further guidance, please refer to Exchange Act Sections Question
116.04 of the
         Division's Compliance and Disclosure Interpretations on our website.
Our Products, page 3

5.       Please disclose the names of your principal suppliers. Please see Item
101(h)(4)(v) of
         Regulation S-K.
Item 2. Financial Information
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
14

6.       Since you have no gross profit please revise to utilize the
descriptive term "gross loss." In
         addition, please quantify each of the cited items of general and
administrative items that
         increased for the year ended December 31, 2018. Lastly, please
quantify ongoing
         operating expenses from liabilities.
Item 5. Directors, Executive Officers., page 21

7.       Please revise your disclosure to describe the business experience of
each director and
         executive for the past five years, including clarifying your
disclosure by adding dates or
         the duration of employment. Refer to Item 401(e) of Regulation S-K.
item 7. Certain Relationships and Related Transactions, and Directors
Independence., page 23

8.       Please provide the disclosure required by Item 404(a) of Regulation
S-K in connection
         with Messrs. Lindauer and Bartholomew and the WW Asset Purchase
Agreements.
Item 7. Certain Relationships and Related Transactions, and Director
Independence., page 23

9.       Please describe in further detail how the Securities Compliance Note
was assigned to
         another entity and who paid and who received the $5,000 in exchange
for the re-
         assignment. In addition, please tell us where this amount is disclosed
in the statement of
         cash flows.
Item 13. Financial Statements and Supplementary Data
Financial Statements, page F-1

10.      Please update your financial statements in accordance with Rule 3-12
of Regulation S-X
         and note the financial statement requirements of Rule 3-02(a) of
Regulation S-X as it
         relates to a predecessor.
 Stavros Triant
FirstName LastNameStavros Triant
Golden Developing Solutions, Inc.
Comapany NameGolden Developing Solutions, Inc.
May 29, 2019
May 29, 2019 Page 3
Page 3
FirstName LastName
Notes to Consolidated Financial Statements
Note 1. Description of Business and Significant Accounting Policies
Revenue Recognition, page F-8

11.      In the Introduction section on page 2, you disclose that through your
online retail
         business, you will offer products, including, but not limited to
traditional vitamins,
         supplements, CBD based tinctures, vapes, and soft-gels; however your
revenue
         recognition policy focuses on revenue from subscription services for
an online and mobile
         cannabis services hub. Please revise your disclosure to clarify how
you currently derive
         revenue and examples of the various services provided. After review of
your response
         and revised disclosure, we may have further comment.
Note 3. Acquisition of Layer Six Media, Inc., page F-12

12.      We note you defaulted on two of the notes payable that were issued in
connection with the
         acquisition. Please revise to disclose the status of the notes and any
additional expenses
         incurred as a result of the default. Please disclose any remedies the
holders of the
         defaulted notes may have against you.
13.      Please disclose how you accounted for the $500,000 payment to the
Director for his
         representation of the sellers in the transaction with reference to
applicable accounting
         guidance.
14.      We note your calculation of aggregate consideration of Layer Six Media
was based, in
         part, upon the face value of notes payable accruing interest at what
appears to be a below
         market interest rate. Please advise how you determined that the face
amount of the notes
         payable of $3.83 million represented the fair value of the notes given
the stated interest
         rate relative to your ability to pay as such notes matured. You also
disclose that you
         valued the common stock portion of the consideration at the closing
market price on the
         date of acquisition. Please explain in detail whether and how you
applied any "big block"
         or liquidity discounts. If you did not apply any discounts, please
explain your rationale
         given the depth of the trading market for your stock. We may have
further substantive
         comment.
15.      Please explain to us in detail why you did not consider Layer Six
Media to be the
         predecessor since it appears you succeed to substantially all of the
business of Layer Six
         Media and your operations before the succession appear insignificant
relative to the
         operations acquired. Refer to Rule 405 of Regulation C.
        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.
 Stavros Triant
Golden Developing Solutions, Inc.
May 29, 2019
Page 4

        You may contact Ta Tanisha Meadows, Staff Accountant, at 202-551-3322
or Jim
Allegretto, Senior Assistant Chief Accountant, at 202-551-3849 if you have
questions regarding
comments on the financial statements and related matters. Please contact Scott
M. Anderegg,
Staff Attorney, at 202-551-3342 or Jacqueline Kaufman, Staff Attorney, at
202-551-3797 with
any other questions.



FirstName LastNameStavros Triant                           Sincerely,
Comapany NameGolden Developing Solutions, Inc.
                                                           Division of
Corporation Finance
May 29, 2019 Page 4                                        Office of Consumer
Products
FirstName LastName