SecProbe.io

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Mail Stop 3561

December 12, 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
		Amendment No. 1 to Schedule 14C
      Filed November 25, 2005
		File No. 0-32137

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.

Summary Term Sheet, page 1

1. You have revised the summary term sheet on page 1 to properly
describe the transaction as a reverse merger; however, the last
sentence of the second paragraph states that Online Vacation
Centers
will be the surviving corporate entity.  Please revise to state
that
Online Vacation Centers will be the accounting survivor and
surviving
business operations; however, Alec Bradley is the surviving legal
entity.

Q: Why is Alec Bradley Cigar Proposing the Reverse Merger?, page 5
2. One of the reasons you list for the reverse merger is that
"performance of Alec Bradley Cigar common stock in the marketplace
has been disappointing."  However, the documents you provided
indicate on pages 22 and 23 that the company outperformed the
Russell
3000 Index, the Tobacco Comparable Companies Index and the
Distribution Comparable Companies Index for the twelve month
period
ended August 30, 2005.  Your internal report also indicated that
the
company outperformed the Russell 3000 Index and the Tobacco
Comparable Companies Index for the 24 month period ended August
30,
2005.  Please reconcile these statements and include additional
disclosure to address these inconsistencies.

Q: What are the risks and disadvantages of the proposals..., page
6
3. Based upon the information you provided to us, it appears that
Online Vacation Centers has not experienced significant growth
over
the past two years, has an accumulated deficit of $2,997,451 as of
August 31, 2005, and has not been successful in prior similar
consolidation attempts.  Please revise to include disclosure about
these risks.  Further, throughout your document, please balance
your
discussion of the business prospects of Online Vacation Centers
with
disclosure of the lack of growth and prior success with
acquisitions
and the accumulated deficit.

Q: Why is Online Vacation Center Proposing the Share Exchange?,
page
6
4. We note that the documents you provided to us indicate that
Online
Vacation Centers has "indicated that its business plan includes
growth through acquisitions of similar companies" and that the
Online
Vacation Centers "intends to finance a significant portion of the
future acquisitions through the issuance of additional common
stock."
Please indicate that Online Vacation Center plans to use
additional
stock issuances in its acquisitions and that these stock issuances
may cause further dilution to current Alec Bradley shareholders.

Q: Why is Alec Bradley Cigar Proposing the Amendment to the
Articles..., page 6
5. This section indicates that preemptive rights may delay or
prevent
future financings and material transactions.  Please indicate in
this
section that the current business plan is to engage in financings
relying heavily on issuances of common stock and that the
elimination
of preemptive rights may cause further dilution to current
shareholders.

Q: Why is Alec Bradley Cigar Proposing the Amendment to the
Articles..., page 7
6. Your disclosure indicates that you have no plans or proposals
for
issuing additional shares of common stock except as pursuant to
the
exchange agreement.  The materials you provided indicate that the
business plan of Online Vacation Centers is to finance a number of
future acquisitions utilizing additional issuances of stock.
Please
reconcile these statements or explain.

Q: What will Happen in the Proposed Reverse Merger?, page 7
7. Please revise to discuss the stock sales involving Mr. Rudner,
Mr.
Ginsberg and a third party and the options to be issued to Messrs.
Rudner and Froelich.

Reasons for the Share Exchange, page 17
8. Your disclosure indicates that Alec Bradley`s common stock has
not
been sufficiently attractive to serve as currency to fund its
growth.
In the second paragraph of this section, you indicate that Online
Vacation Centers believes that as a public company, its common
stock
may be used as consideration for the acquisition of other travel
companies.  Please tell us why the common stock was not sufficient
to
serve as currency for Alec Bradley, but would be sufficient for
Online Vacation Centers purposes.

The Share Exchange Agreement, page 17
Effects of the Share Exchange, page 17
9. We note your response to comment 23 in our letter dated
November
9, 2005. We reissue our comment asking you to describe the terms
of
the conversion, since the debentures are not described in the
share
exchange agreement.

Fairness Opinion, page 25
10. We note your response to comment 26 in our letter dated
November
9, 2005.  Please disclose the proposed number of shares to be
issued
as a result of each analysis, and revise to specify how each of
the
analysis concluded that the consideration of 2.7 million shares
for
the asset sale and 15 million shares for the share exchange was
fair
to the unaffiliated shareholders.

Benefits under the Plan to be received..., page 44
11. We note your response to comment 33.  We note that in footnote
(4) to the ownership table on page 9, Mr. Froelich also has a
right
to options.  Please revise to include the information for Mr.
Froelich on page 44, or advise us.

Pro Forma Unaudited Condensed Consolidated Financial Information,
page 58

12. Please revise the first sentence of the first paragraph on
page
58 to indicate that it is only the pro forma balance sheet that
assumes the transaction took place on September 30, 2005.

13. Please revise the pro forma balance sheet to include a
footnote
explaining why you are making an adjustment for the subordinated
debentures.  We believe your disclosure should include a statement
as
to why you are assuming this conversion, even though the terms of
the
debentures do not provide for any conversion.  If it is a
condition
to the share exchange, please state this fact.  You should also
disclose the number of pre merger Online Vacation Centers shares
to
be issued, and highlight the fact that this will not impact the
number of shares to be outstanding after the share exchange is
completed.

14. Since you are making a pro forma adjustment for the debentures
it
appears you should make a corresponding change in the pro forma
income statements for the interest expense associated with the
debentures.  Please revise or advise.

15. Please revise the first sentence of the interim period pro
forma
statement of operations to state that you assumed the transactions
occurred as of January 1, 2004, not January 1, 2005.

16. Please expand the disclosure with respect to the stock options
to
disclose the exercise price.  Since the options have an exercise
price in excess of fair value, please revise your disclosure to
state
how you determined the number of shares you used in the fully
diluted
earnings per share calculation.

Schedule of Comparative Per Share Information, page 61

17. Please revise to disclose that the book value information is
as
of September 30, 2005.

18. Please revise to adjust Online Vacation Centers per share
information as if they had 15 million shares outstanding.  It
appears
this is necessary in order to comply with Instruction 2 to Item
14(b)(10) of Schedule 14A.  In effect, it appears that this would
be
the same result as if Online Vacation Centers declared a stock
split
which resulted in 15 million shares outstanding and the exchange
rate
was one-to-one.  Please add disclosure explaining this treatment,
or
advise.

19. We believe it is appropriate to calculate Alan Rubin`s "after"
amounts for earnings per share by using 2,895,000 shares.  Please
revise the disclosure to reflect this assumption.  We believe this
is
necessary to reflect the fact that his interest in earnings before
the transaction was 64%, and it is 100% after the transactions.
If,
due to rounding, Rubin`s earnings per share does not change,
please
add a footnote explaining why.

Financial Statements of Online Vacation Centers

20. We note your response to comment 43 from our November 9, 2005
comment letter.  Please either revise the annual financial
statements
to provide disclosure of the restricted cash, or tell us why this
disclosure is only required in the interim financial statements.
Also, based on your explanation, it is not clear why the
restricted
cash qualifies as a current asset.  Please tell us how the
restricted
cash is available to pay current liabilities or revise the
financial
statements to reclassify as a non current asset.

21. We have read your response to comments 34 and 44 from our
November 9, 2005 comment letter; however, we believe the statement
of
cash flows should separately disclose the cash and non cash
elements
of the settlement obligation.  Also, please revise the footnote to
disclose when you recorded the expense and to reconcile the
activity
in 2004.

22. We note the paragraph you added on page 51 in management`s
discussion and analysis with respect to your income tax valuation
allowance; however, we do not see any change in your footnote
disclosure in either your annual or interim financial statements.
We
also note that management`s judgments with respect to the
valuation
allowance resulted in a very significant portion of your net
income
in each of the past two years and the nine month period ended
September 30, 2005.  We believe that significant revision to your
document is required in order for a reader to understand the
impact
of your income tax accounting.  For example, your document does
not
address this issue in your critical accounting policies and you do
not discuss this in your Results of Operations section of your
management`s discussion and analysis for each period presented.
Please revise these discussions in addition to the financial
statements to quantify the valuation allowance and explain how you
comply with paragraph 17(e) of SFAS 109.  We may have additional
comment.

*********

      As appropriate, please amend your filing 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
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.

      You may contact Robert Burnett, Staff Accountant, at (202)
551-
3330 or Donna Di Silvio, Senior Staff Accountant, at (202) 551-
3202
if you have questions regarding comments on the financial
statements
and related matters.  Please contact Lisa Beth Lentini, Attorney-
Advisor, at (202) 551-3334, Peggy Kim, Senior Attorney, at (202)
551-
3411, or me at (202) 551-3720 with any other questions.

								Sincerely,

								H. Christopher Owings
								Assistant Director

Cc:	Brian Pearlman, Esq.
	Adorno & Yoss
	Fax: (954) 766-7800

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Alan Rubin, Principal Executive Officer
Alec Bradley Cigar Corporation
December 12, 2005
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