September 6, 2019

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

       Re: Golden Developing Solutions, Inc.
           Amendment No. 2 to Form 10-12G
           Filed August 14, 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 and any amendment you may file in response
to these
comments, we may have additional comments.

Form 10-12G/A Filed August 14, 2019

Notes to Consolidated Financial Statements (Annual)
Note 1. Summary of Significant Accounting Policies
Revenue Recognition, page F-8

1.    We reviewed your response to prior comment three. Please tell us and
revise your
      revenue recognition policy to clarify the point in time in which you
satisfy your
      performance obligations and how you recognize subscription revenues. In
this regard, as
      noted in your disclosures, the large majority of the Company's
performance obligations
      are recognized over a time period equal to the length of the subscription
period, which is
      generally 30 days, beginning on the date that the service is made
available to the
      customer. Your revised revenue recognition policy should also describe
the payment
      terms and conditions associated with your subscription arrangements. For
      instance, explain whether your customers typically pay an upfront annual
subscription fee
 Stavros Triant
FirstName LastNameStavros Triant
Golden Developing Solutions, Inc.
Comapany 6, 2019
September NameGolden Developing Solutions, Inc.
Page 2
September 6, 2019 Page 2
FirstName LastName
         or pay as they go on a monthly basis, and whether or not any of the
fees are non-
         refundable. In addition, to the extent that any of the deferred
revenue balances at each
         period end relates to website services, please provide examples of
remaining performance
         obligations and how deferred revenue for that portion is calculated
and recognized.
Note 3. Acquisition of Layer Six Media, Inc., page F-12

2.       Please provide audited financial statements for Layer Six Media, Inc.
for the appropriate
         periods based on significance in accordance with Rule 3-05 of
Regulation S-X. In this
         regard, please show us via calculation how you determined significance
for the number of
         audited years presented.
Note 1. Description of Business and Significant Accounting Policies
Revenue Recognition, page F-22

3.       We note customers are able to pre-order some products at
www.wheresweed.com and full
         payment is due upon delivery or customer pick-up. Please clarify in
your disclosures if
         the products on this online site are related to the Infusionz
acquisition and whether this is
         the only method of product sales. Additionally, please include whether
Cost of Revenues
         on page F-23 includes any costs associated with product sales, such as
warehouse and
         distribution costs and how and when finished goods inventory is
reflected in Cost of
         Revenues.
Notes to Consolidated Financial Statements (Interim)
NOTE 2 - GOING CONCERN AND LIQUIDITY
Infusionz Acquisition, page F-26

4.       Please supplementally demonstrate whether the acquisition of Infusionz
was significant
         pursuant to Rule 3-05 of Regulation S-X. Please be detailed in your
calculations. We
         may have further comment.
        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.

       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.
 Stavros Triant
Golden Developing Solutions, Inc.
September 6, 2019
Page 3

       Please contact Scott 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
September 6, 2019 Page 3                                 Office of Consumer
Products
FirstName LastName