August 17, 2005

James O`Leary
Executive Vice President and Chief Financial Officer
Beazer Homes USA, Inc.
1000 Abernathy Road, Suite 1200
Atlanta, GA 30328

	Re:	Beazer Homes USA, Inc.
      Form S-4 filed August 3, 2005
      File No. 333-127165

Dear Mr. O`Leary:

      We have limited our review of your filing to those issues we
have addressed on our comments.  Where indicated, we think you
should
revise your documents in response to these comments.  If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We
look forward to working with you in these respects.  We welcome
any
questions you may have about our comments or on any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

General

1. Provide us with an executed supplemental letter that:
* states you are registering the exchange offer in reliance upon
the
relevant Exxon Capital no-action letters, and
* includes the representations substantially in the form set forth
in
the Morgan Stanley and Shearman & Sterling no-action letters.

Legal Matters, Page 82

2. Please revise to disclose that counsel will pass upon whether
the
notes and guarantees will be the binding obligations of the
issuers.

Exhibit 5.1 - Paul Hastings Legal Opinion

3. You cannot assume provisions (ii) (as related to the non-
Georgia/Delaware guarantors), (x) and (xi), but you can expressly
rely
on other opinions. Each such other opinion must reflect that you
are
permitted to rely on it.

4. Please delete as inappropriate provision (ix). Furthermore, the
opinion already contains a bankruptcy exception and equitable
principles limitation.

5. Since you say the Guarantees will constitute "valid" and
binding
obligations of the Non-Georgia/Delaware Guarantors, you should use
the
same language in paragraph 3.

6. In the penultimate paragraph, either remove the words "as of
the
date hereof" or refile an opinion on the day you want the
registration
statement to go effective. Please make similar revisions in
Exhibits
5.2 through 5.9.

7. You can limit reliance with regard to purpose, but not person.
Please revise. This comment also applies to Exhibits 5.3, 5.4, 5.5
and
5.8.

8. Where counsel refers to the Delaware General Corporation Law,
counsel should confirm supplementally that it does not intend to
exclude the Delaware Constitution and reported judicial decisions
interpreting these laws.  Counsel should file this correspondence
on
EDGAR, as it will be a part of the Commission`s official file
regarding this registration statement.  See Section VIII.A.14 of
our
November 14, 2000 Current Issues Outline.

Exhibit 5.3 - Hogan & Hartson Opinion

9. Please delete as inappropriate provisions (i) - (iv).

10. Please delete as inappropriate the qualification that counsel
expresses no opinion on antitrust, unfair competition, banking or
tax
laws or regulations.

11. Please delete the words "in our experience" from the 6th
paragraph. This comment also applies to exception D in Exhibit
5.4.

12. The opinion that the guarantor is validly existing and in good
standing should be as of the effective date. This comment also
applies
to Exhibit 5.4.

Exhibit 5.4 - Gibbons Opinion

13. Please delete as inappropriate the paragraph about the meaning
of
"knowledge." This comment also applies to Exhibit 5.5, 5.7, and
5.8.

14. Please delete as inappropriate exception A. We would not
object,
however, if counsel carved out federal and state blue sky
securities
law matters.

	As appropriate, please amend your filing in response to these
comments.  You may wish to provide us with marked copies of the
amendment to expedite our review.  Please furnish a cover letter
with
your amendment that keys your responses to our comments and
provides
any requested information.  Detailed cover letters greatly
facilitate
our review.  Please understand that we may have additional
comments
after reviewing your amendment and responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have
made.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

?	should the Commission or the staff, acting pursuant to
delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any 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 this action as a defense in any
proceeding initiated by the Commission or any person under the
federal
securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division
of Corporation Finance in connection with our review of your
filing or
in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering of
the securities specified in the above registration statement.  We
will
act on the request and, pursuant to delegated authority, grant
acceleration of the effective date.

	We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Brigitte Lippmann at (202) 551-3713 or me at
(202) 551-3760 if you have any questions.

Sincerely,



Pamela A. Long
Assistant Director


cc:	Elizabeth Noe, Esq.
	Paul, Hastings, Janofsky & Walker LLP
	600 Peachtree Street, N.E., Suite 2400
	Atlanta, GA 30308

??

??

??

??

James O'Leary
Beazer Homes USA, Inc.
August 17, 2005
Page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE