SecProbe.io

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							March 3, 2005

via facsimile and U.S. mail

Mr. Russell L. Smith
Chief Executive Officer
O`Hara Resources, Ltd.
4333 Admiralty Way, Suite 100P
Marina del Ray, CA 90291

	Re:	O`Hara Resources, Ltd.
		Form 10-KSB, Filed January 27, 2005
		Form 10-QSB, Filed January 28, 2005
		File No. 000-16602

Dear Mr. Smith:

      We have reviewed the above filings and have the following
comments.  Our review has been limited to the areas commented on
below.  Where indicated, we think you should revise your document
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
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not 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. Please update the address of your principal executive offices
and
telephone number on the EDGAR Filer website, located at
https://www.edgarfiling.sec.gov.

10-KSB for the year ended April 30, 2004

Management`s Discussion and Analysis, page 4

2. We note that although we previously advised you of your
reporting
obligations under Item 303(a) of Regulation S-B, you continue to
refrain from providing the required disclosures.  As you know,
given
your financial condition, this guidance requires that you include
disclosure in your filing describing your plan of operation for
the
next twelve months.  Your disclosures should address the following
information:

a) A discussion of how long you can satisfy your cash requirements
and whether you have to raise additional funds in the next twelve
months.

b) A summary of any research and development that you will perform
during the next twelve months.

c) A discussion of any expected purchases or sales of fixed assets
to
occur within the next twelve months.

d) A discussion of any expected significant changes in the number
of
employees to occur within the next twelve months.

Further, since you currently have no operations or employees, it
is
unclear how you are able to support presenting your company as a
going concern.  We are unable to locate any disclosure explaining
how
you plan to overcome your financial difficulties, as would
ordinarily
be required under Financial Reporting Codification Section 607.02.
As such, it appears that you should also revise your filing to
include the disclosures required under this guidance.  If you have
no
such plans, tell us how you believe your presentation would need
to
change to report on a liquidation basis.

Independent Auditor`s Report

3. It appears that your independent accountants merged sometime in
February 2004.  As a result, you are required to file an Item 4.01
Form 8-K.  Please file the appropriate Form 8-K to announce the
change in your independent accountant, as appropriate.

Financial Statements

Statement of Stockholders` Equity (Deficit)

4. We note that summations of the amounts under the headings for
"Shares," "Capital Stock Amount," "Deficit Accumulated Additional
Paid-in Stage," and "During the Development Total" do not equal
the
totals indicated.  Your columnar headings also appear to require
correction.  Please review these items and make the proper
revisions
to this statement.  Also address the following points.

a) We note your statement on page 4, concerning your decision to
rescind the purchase of GlobalLink Technologies Ltd., that "All
stock
tendered by the Company pursuant to the aforementioned Stock
Purchase
Agreement has since then been voluntarily returned to the
Company."
Tell us how you have reflected the shares applicable to the Stock
Purchase Agreement you entered into in November 2003, and the
subsequent cancellation of the acquisition in early 2004.

b) Explain how you have reflected the 300,000 shares issued in the
agreement to acquire Mountain States Petroleum Corporation ("MSP")
and the subsequent write-off of the option to acquire MSP entered
into in November 2002, valued at $1,650,000.

Item 8A. Controls and Procedures

5. Please amend your filing to include the information regarding
disclosure controls and procedures and internal control over
financial reporting required by Items 307 and 308 of Regulation S-
B.

Exhibit 31.1

6. We note that your certification pursuant to Section 302 of the
Sarbanes-Oxley Act of 2002 refers throughout to your quarterly
report
instead of your annual report and the wording does not precisely
match the language set forth in the Act.  Refer to Item 601(b)(31)
of
Regulation S-B for the exact text of the required Section 302
certification, and amend your exhibit as appropriate.  In the
event
you are unable to provide the certification, disclose the reasons,
steps you are taking to remedy the situation, and the date you
expect
to be able to comply with your reporting obligations.

10-QSB for the periods ended October 31, 2004

General

7. Revise your Form 10-Q for any applicable comments noted under
your
Form 10-K.

Closing Comments

      As appropriate, please amend your filings and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
amendments to expedite our review.  Please furnish a cover letter
with your amendments that keys your responses to our comments and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendments 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 the company`s disclosure, they
are responsible for the accuracy and adequacy of the disclosures
they
have made.  In connection with responding to our comments, please
provide, in writing, a statement from the company acknowledging
that:

the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filing; and

	the company may not assert staff comments 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 our review of your filings or
in
response to our comments on your filings.

      You may contact Jennifer Goeken at (202) 824-5287 or Karl
Hiller at (202) 942-1981 if you have questions regarding comments
on
the financial statements and related matters.  Please contact me
at
(202) 942-1870 with any other questions.  Direct all
correspondence
to the following ZIP code:  20549-0405.

							Sincerely,

							H. Roger Schwall
							Assistant Director

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O'Hara Resources, Ltd.
March 3, 2005
page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE

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