SecProbe.io

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Mail Stop 3561

December 28, 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. 2 to Schedule 14C
      Filed December 21, 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.

Questions and Answers..., page 4

Q: Why is Alec Bradley Cigar Proposing the Reverse Merger?, page 5

1. We note your response to comment 3 in our letter dated December
12, 2005.  We reissue a portion of the comment.  Please revise
your
disclosure to indicate that to date, Online Vacation Centers has
not
acquired any businesses.

The Share Exchange Agreement, page 18

General Terms, page 17
2. We note your response to comment 9 in our letter dated December
12, 2005. We reissue our comment asking you to describe the terms
of
the debenture conversion.  We note that all of the shareholders of
Online Vacation and the debenture holder will receive an aggregate
of
15,000,000 shares of Alec Bradley common stock.  Please disclose
the
number of shares that the debenture holder will receive in
exchange
for the $3 million debenture.  Please also disclose the number of
shares of Online Vacation that are currently outstanding.

Pro Forma Unaudited Condensed Consolidated Financial Information,
page 62

3. In making revisions in response to comment 14 from our letter
dated December 12, 2005, you eliminated interest expense related
to
the debentures from the historical Online Vacation Center column
on
page 64.  Please revise the pro forma information to show the
interest expense as a pro forma adjustment and show the historical
column the same as the interim and audited annual financial
statements.

4. It is not clear why the fully diluted number of shares has been
adjusted for stock options that are exercisable at a price in
excess
of market value.  Please revise to explain or to disclose why you
have not included these potential shares in the fully diluted
calculation.

Schedule of Comparative Per Share Information, page 65

5. Please revise the schedule on page 65 to define EPS and to
clarify
that the 2004 amounts are for the entire year, not just the nine
month comparative to the 2005 amounts.

Financial Statements of Online Vacation Centers

6. We note you have revised the classification of restricted cash
from current assets to non-current assets in your annual and
interim
financial statements.  Please tell us what consideration you gave
to
APB 20 or revise if appropriate.

7. Please revise the disclosure in the fourth paragraph of the
Income
tax footnote on page 10 of Online Vacation`s annual financial
statements to define what SARS refers to and why it impacted your
valuation allowance analysis.

8. We note your revisions to your income tax disclosure and the
revisions to your historical financial statements in the second
and
third quarters in 2005.  Your decision to adjust the valuation
allowance results in restated financial statements as the result
of a
correction of an error.  Please revise your interim financial
statements to provide the disclosures required by APB 20,
paragraph
37 and label the financial statements as restated.  See also EITF
D-
86.

9. Please expand your disclosure in either the notes to financial
statements, Management`s Discussion and Analysis, or both if
appropriate, to quantify the effect on pre tax income of
management`s
judgments with regard to the valuation allowance.  For example,
you
currently disclose the percentage of the valuation allowance
meeting
the more likely than not standard; however, with a view towards
transparent disclosure, please quantify the dollar impact.

*********

      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 28, 2005
Page 1

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