SecProbe.io

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Mail Stop 3561

November 9, 2005

Alan Rubin, Principal Executive Officer
Alec Bradley Cigar Corporation
3400 S.W. 26th Terrace, #A-1
Dania, FL  33312

      Re:	Alec Bradley Cigar Corporation
		Schedule 14C
      Filed October 12, 2005
		File No. 0-51511

Dear Mr. Rubin:

      We have reviewed your filing and have the following
comments.
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
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 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 tell us what exemption from registration you are relying
upon for the issuance of shares in the share exchange and describe
the facts that make the exemption available to you.

2. Please include, in the first few pages of your information
statement, a summary term sheet that describes only the most
material
terms of the proposed merger transaction in bullet point format.
Refer to Item 1001 of Regulation M-A and also Section II.F.2 of
Securities Act Release No. 7760 for a list of other issues that
may
be appropriately disclosed in the summary term sheet.

Questions and Answers, page 1
3. Your question and answer section repeats information found in
your
summary section.  Please treat the two sections as one summary
section and consolidate like information while eliminating
repetition.
4. Please clarify, in the summary and throughout your document,
that
the share exchange is a reverse merger in which the Online
Vacation
will be the surviving company.  Further, please describe the
change
of control in connection with the reverse merger.  Specifically
address how management and the business will change, that current
shareholders of Alec Bradley will experience substantial dilution,
and disclose that current shareholders of Alec Bradley will
collectively own only 9% of Online Vacation after the share
exchange.
5. Please revise to state in the summary whether the proposed
amendments to your articles and the adoption of your equity plan
are
contingent on the asset sale and share exchange with Online
Vacation.
6. Please revise to briefly describe, in the summary and under
your
discussion of the asset sale and share exchange, your plans if the
asset sale and merger agreement are not consummated.
7. We note that you state that your stock is "listed" on the
OTCBB.
For example, refer to pages 1, 3, 6, 13, and 17.  Please revise to
clarify that stock prices are "quoted" on the OTCBB.

Q: Why are Alec Bradley Cigar and Online Vacation..., page 2
8. Please revise to clarify how the reverse merger will result in
giving your shareholders "a greater chance of realizing
shareholder
value than if we continue with our current cigar business" and
providing Online Vacation`s shareholders with "greater liquidity"
and
"greater access to capital markets."

Q: What will happen in the proposed share exchange?, page 3

9. In the eighth question, you disclose the $78,000 of related
party
notes that Mr. Rubin will forgive.  Please tell us if this is part
of
the agreement or the basis for stating this matter.  We note the
debt
is due in the normal course by December 31, 2005 and Mr. Rubin
will
own 100% of the cigar business after the transactions are
completed.
Please revise to update the balance of promissory notes and
clarify
the significance of this matter in determining the sales price of
the
cigar business.

Q: What will Online Vaction Center shareholders receive..., page 3
10. Please also disclose that current Alec Bradley`s shareholders
will not receive any stock or consideration in connection with the
asset sale or merger agreement and will hold stock in a new
company,
Online Vacation Center, after the reverse merger.

What are the implications of the proposals for Alec Bradley
Cigar`s
current..., page 3
11. Please revise your statements about Alec Bradley`s cigar
business
continuing after the asset sale to clarify that your current
stockholders will no longer hold any interest in the cigar
business
after the asset sale.

What are the risks to the proposals, page 3
12. Please revise your statements under the answer to this
question.
We note that you state that Mr. Rubin is not withdrawing from the
cigar business and that your decision to withdraw from the cigar
business may be premature.  Please clarify that your current
stockholders will no longer hold any interest in Mr. Rubin`s cigar
business after the asset sale.  Further, please revise to clarify
what you mean in the last two sentences.

Summary of the Sale of Assets, page 5
13. Please describe in reasonable detail any negotiations, and any
present or proposed agreement, arrangement, or understanding
between
Mr. Rubin and either you or your affiliates concerning the sale of
assets transaction.  In this regard, explain how you determined
the
sale price of 2.7 million shares and $78,000 of forgiveness in
debts
owed by the company and discuss the fairness of the consideration.
Refer to Item 15(b) of Schedule 14A.
14. Please state whether you considered any alternative
transactions
to the asset sale.  If so, describe them and explain why they were
eventually rejected, and if you have not considered any other
transaction, explain why not.
15. Please provide bullet-point lists, discussing the material
advantages and disadvantages both to you and to your shareholders
arising from the asset sale.

Interests of Certain Persons in the Share Exchange, page 7
16. Please describe any interests and benefits to affiliates of
Alec
Bradley and Online beyond stock ownership.
17. Footnote 2 indicates that Mr. Rudner may purchase privately
from
two third party shareholders, common stock at a price of $0.90 and
at
a price of $0.20.  Please explain the disparity in prices for the
shares and tell us whether there is an agreement currently in
place
for the purchase of the shares.  Additionally, please identify
whether any of the third parties are affiliates of Alec Bradley
Cigar.  In particular, please note whether the 500,000 shares Mr.
Rudner may purchase at a price of $0.90 represents the interests
of
Mr. Ginsberg.

Accounting Treatment, page 8

18. Please state the accounting treatment under generally accepted
accounting principles.  Please revise to present the accounting
treatment from the point of view of the surviving accounting
entity.
For example, it appears you should disclose that the share
exchange
will be accounted for as a reverse acquisition, if so, with Online
Vacation Center as the surviving entity for accounting purposes
and
the assets and liabilities of Online Vacation Center carried
forward
at historical costs.  Please revise or advise.

Cautionary Statement Concerning Forward Looking Information, page
11
19. We note your reference to the Private Securities Litigation
Reform Act.  Section 21E(b)(1)(C) of the Securities Exchange Act
of
1934 expressly states that the safe harbor for forward looking
statements does not apply to statements made with respect to the
business or operation of an issuer if the issuer issues penny
stock.
Please delete references to the Litigation Reform Act.

Proposal One: Sale of Assets, page 13
20. Please include the information required by Item 202(a) of
Regulation S-B and describe the effect of the penny stock rules on
the trading of your common stock.
21. Please describe any material differences in the rights of
security holders as a result of the reverse merger with Online
Vacation.

Background of the Share Exchange, page 14
22. Please describe any past contacts, transactions, or
negotiations
with Online Vacation.  Refer to Item 14(b)(7) of Regulation M-A.

Effects of the Share Exchange, page 15
23. We note that $3 million of outstanding Online Vacation
debentures
will be converted into the common stock of Alec Bradley.  Please
describe the terms of conversion.

Representations and Warranties, page 16
24. Please remove the term `certain` from your disclosure and
replace
with more definite language.

Interests of Certain Persons in the Share Exchange, page 23

25. In footnote 6, you indicate that shares held by the Cataldo
Family Trust are not included in the total.  Please tell us why
Cataldo Family Trust shares have been excluded.

Fairness Opinion, page 24
26. As currently drafted, the discussion of Capitalink`s opinion
does
not provide a meaningful summary of each of the analyses
performed.
Please revise Capitalink`s summary so that it is written in clear,
understandable language.  Avoid unnecessary financial terms that
make
the disclosure very difficult to understand.  Rather, explain in
clear, concise, and understandable language what the financial
advisor did and how the analysis and conclusion are relevant to
stockholders and specifically to the consideration offered.  As
part
of the revisions, please describe the purpose of each analysis and
why particular measures were chosen for analysis.  For example,
please describe how equity value and enterprise value were
calculated
and weighed, and why particular multiples or discounts were used
in
each analysis.
27. You attempt to qualify by the entirety the discussion of
Capitalink`s methods use to determine fairness of the transaction
by
referring to the fairness opinion letter.  However, it appears
that
the fairness opinion letter does not include a thorough discussion
of
the methods used to determine fairness.  Please remove the
qualification.  Your disclosure should be accurate and complete.

28. Please provide us with copies of all material non-public
information, including board books, projections and other
materials
exchanged among and relied upon by the parties.
29. Provide us with any analyses, reports, presentations, or
similar
materials prepared for or by the financial advisors in connection
with rendering each fairness opinion. In particular, please
provide
us with copies of the presentation and any materials presented on
September 30, 2005.
30. Please discuss the negotiation process regarding the exchange
ratio, including the possible exchange ratios that were
considered.
31. Please describe the method of selecting Capitalink.  Refer to
Item 1015(b)(3) of Regulation M-A.  Please also describe any
material
relationship between Capitalink and either you or Online Vacation.
Refer to Item 1015(b)(4).  In addition, describe any instructions
or
limitations that Capitalink received from either you or Online
Vacation.  Finally, please disclose the fee paid for the fairness
opinion.

Proposal Two: Approval of Amendment to the Articles of
Incorporation
to..., page 37
32. Please describe the anti-takeover effect of preemptive rights.

Proposal Five: Adoption of the 2005 Management an Director
Equity...,
page 41
33. Please revise to include the information required by Item
10(a)(2) of Schedule 14A.

Legal Proceedings, page 50
34. Please describe the underlying legal proceeding that you refer
to
on page 50 including the names of the parties, the claim made and
location of the trial.  Additionally, please tell us why the
settlement caused you to recognize a gain.

Pro Forma Financial Information, page 61

35. Please revise the headnote on page 61 to state that the pro
forma
balance sheet assumes the transactions occurred as of June 30,
2005
(or September 30, 2005 when updated financial statements are
required).  The pro forma statements of operations should assume
the
transactions occurred at the beginning of the earliest year
presented. i.e. January 1, 2004.  Please revise.

36. Please revise to include a pro forma statement of operations
for
the year ending December 31, 2004, or tell us why you believe it
is
not required.  See Item 310(d) of Regulation S-B.

37. Please revise the third column heading on page 62 to define
"ABDC."

38. Please revise to include a footnote or schedule showing the
historical number of shares outstanding as of the most recent
balance
sheet and reconciling to the number of common shares that will be
outstanding upon completion of the transactions.

39. Please clarify why there is a pro forma adjustment eliminating
the 4.5 million Alec Bradley shares since that is the legal entity
and only 2.7 million shares will be eliminated in the sale of
assets.
Include a footnote stating the number of shares of Alec Bradley
issued in exchange for the outstanding shares of Online Vacation.
Please revise accordingly.

40. It is not clear why the average number of outstanding common
shares, as shown on page 63, is different for the basic earnings
per
share calculation versus the fully diluted calculation.  Please
revise to include a footnote explaining what gives rise to the
difference.

41. Please revise to include a footnote with respect to the $3
million of subordinated debentures. If it is probable that the
debentures will be converted to Online Vacation Center common
stock
as indicated in Note 11 to the interim financial statements, then
you
should show the pro forma effect of such a conversion including an
adjustment for the related interest expense.

42. Please revise to show comparative per share information
showing
how the proposed transactions will impact shareholders of Online
Vacation Centers and Alec Bradley.  It appears you should show the
impact of Mr. Rubin separately from the other current public
shareholders of Alec Bradley.  See Item 14(b)(10) of Schedule 14A.

Financial Statements of Online Vacation Centers, page F-1

43. Please revise to include a footnote explaining what the
restricted cash relates to, how it is restricted and what event(s)
will result in the release of the restriction(s).  We note your
accounting policy with respect to cash and cash equivalents that
cash
in the bank relates to cash and cash equivalents, and presumably
not
to restricted cash.  Tell us where the restricted cash is held.

44. Please provide us with additional information with respect to
the
settlement obligation and revise your disclosures, as appropriate,
to
clarify certain matters as we understand them.  Please reconcile
the
activity in the settlement obligation account in 2004.  Please
confirm our understanding that the balance in the obligation
account
arose from accruals of expense in prior periods.  If this is the
case, then it appears that the  characterization of the reversal
of
over accruals as a "gain" is not appropriate.  Please revise
management`s discussion and analysis and/or the financial
statements
to clarify this point.  Tell us how you determined the timing and
amount of the initial accruals and when you determined to reverse
these accruals.  Finally, it appears that the statement of cash
flows
in 2004 should separately disclose the non cash adjustment of the
liability balance.  Please revise or advise.

45. Please confirm that Online Vacation Centers has no items of
other
comprehensive income.  You may want to disclose this fact, if
true.

46. Please tell us about the nature of the capitalized relocation
costs and your basis for capitalization or revise as necessary.
See
AICPA Technical Practice Aids Section 5290.04.

47. We note that there is no disclosure in Note 8 on page F-14 of
any
provision to convert the subordinate debentures into common stock
of
Online Vacation Centers.  Please expand to disclose all pertinent
terms of the notes.  Revise your disclosure as ap