SecProbe.io

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

                                                                   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
aspects. 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.

H. Roger Schwall
Assistant Director
Securities Exchange Commission
Washington, DC 20549-0405

Dear Mr. Schwall

Thank you for the comment letter of March 3rd.

The Company has endeavored to comply in its reporting obligations and we
recognize our shortcomings. The Sarbane Oxley requirement has not made it any
simpler. We understand that small business companies have an extension of one
year to implement Sarbane Oxley! The Company will file an amended 10K and 10Q as
requested for the period with the corrections and additions which you have
brought to our attention.

Those corrections and additions are in the form of answers following each titled
question.

Sincerely

Russell Smith
President and CEO

                                       1
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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.

     RESPONSE. OUR CORPORATE ADDRESS IS : 4333 ADMIRALTY WAY SUITE #100P, MARINA
     DEL REY, CA 90292 PHONE 310.821.2244 FAX 419.831.2241

     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 Regulations S-B, you continue to refrain
     from providing the required disclosures. As you know, given your financial
     condition this guidance requires 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.

         RESPONSE. THE COMPANY PLANS TO RAISE FUNDS FROM THE SALE OF ASSETS
         ACQUIRED IN RECENT ACQUISITION OF VISION ENERGY GROUP AND WHEN
         APPROPRIATE FROM PROJECT LOAN FUNDS. THESE DISCUSSIONS WILL BE ADDED TO
         THE REVISIONS OF THE 10-KSB AND 10-QSB.

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

         RESPONSE. FINALIZING THE DESIGN OF THE COMPANY'S LETDOWN ENERGY
         RECOVERY SYSTEM (LER), ORGANIC RANKIN CYCLE (ORC) HEAT RECOVERY SYSTEM
         AND THE LANDFILL GAS TO LIQUID NATURAL GAS (LNG) SYSTEM.

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

         RESPONSE. THE SALE OF ASSETS ACQUIRED IN RECENT ACQUISITION OF VISION
         ENERGY GROUP.

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

         RESPONSE. EXECUTIVE MANAGEMENT WILL CONTINUE ITS RESPONSIBILITIES AND
         ALL OTHER PERSONNEL WILL BE OUTSOURCED.

     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.

     RESPONSE; SEE "2D" ABOVE.

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
     accountants as appropriate.

     RESPONSE; THE COMPANY WAS UNAWARE OF THIS REQUIREMENT AS THE NAME AND
     ADDRESS OF THE COMPANY AUDITORS HAS NOT CHANGED AND THEY HAVE BEEN THE
     COMPANY AUDITOR FOR MANY YEARS. THE AUDITORS HAVE PROVIDED A FORM 8K WITH
     THE REQUIRED INFORMATION AND THE COMPANY WILL FILE IT PROMPTLY. THANKYOU
     FOR MAKING THE COMPANY AWARE OF THIS REQUIREMENT.

                                       2
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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.

     RESPONSE. OUR ACCOUNTANT HAS BEEN REQUESTED TO PROVIDE THE REQUIRED
     INFORMATION AND IT WILL BE INCLUDED IN THE REQUIRED AMENDMENT.

     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 them 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.

         RESPONSE. ALL THE SHARES WERE RETURNED TO THE TREASURY AND THE AND ARE
         REFLECTED IN THE STATEMENT OF THE OUTSTANDING SHARES AS RECORDED IN THE
         TRANSFER AGENTS RECORDS. THESE HAPPENED IN THE SAME FISCAL YEAR AND
         THEREFORE THE NET EFFECXT IS $-0-.

     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.

         RESPONSE. THE SHARES ISSUED TO MOUNTAIN STATES PETROLEUM (MSP) WERE
         RETAINED BY MSP WHEN THE OPTION TIME RAN OUT AFTER SEVERAL EXTENSIONS.
         THE COMPANY COULD NOT REACH AGREEMENTS TO FUND THE ACQUISITION. THIS
         DISCUSSION WILL BE UPDATED IN THE AMENDMENT.

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.

     RESPONSE. THE COMPANY HAS INQUIRED OF ITS AUDITORS FOR THE CORRECT
     PROCEDURES. THESE RECOMMENDED PROCEDURES WILL BE FOLLOWED AT ALL TIMES.

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.

     RESPONSE. THE COMPANY WILL CORRECT THE WORDING OF THE SARBANE-OXLEY
     STATEMENTS AND WILL FOLLOW THE CORRECT WORDING IN ALL FILINGS.

                  10-QSB FOR THE PERIOD ENDED OCTOBER 31, 2004

GENERAL

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

     RESPONSE. THE COMPANY IS FILING A REVISED 10Q WITH LANGUAGE REFLECTING THE
     CHANGES!

                                       3
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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 wish
to provide us with marked copies of amendments to expedite our review. Please
furnish a cover letter with your amendments that days your responses to our
comments and provides any requested supplemental informal. Detailed cover
letters greatly facilitate our review. Please understand that we may have
additional comments after reviewing your amendments and responses to our
comments

         RESPONSE. THE COMPANY WILL FILE AMENDED 10K AND 10Q FOR THE PERIOD.
THESE WILL BE DONE BEFORE THE END OF MARCH 2005.

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 we 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 comment, or changes to disclosures 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,

                                                     JILL S. DAVIES, for
                                                     H. Roger Schwall
                                                     Assistant Director

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