SecProbe.io

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      May 13, 2005

Joseph A. Cosio-Barron, Esq.
President
Consumer Direct of America
Las Vegas, Nevada

RE:	Ocean West Holding Corporation
	Preliminary Information Statement filed April 29, 2005
	File No. 0-49971

Dear Mr. Cosio-Barron:

Because Consumer Direct of America controls Ocean West Holding
Corporation, I am directing our comments regarding the above
referenced filing to you.  I have reviewed the above referenced
document and have the following comments.  Please file Revised
Preliminary Information Statement in response with these comments.
We may have further comment based upon your responses.

Information Statement
General

1. Item 1 of Schedule 14C states, in part: "Furnish the
information
called for by all of the items of Schedule 14A of Regulation 14A
...
which would be applicable to any matter to be acted upon at the
meeting if proxies were to be solicited in connection with the
meeting.  Notes A, C, D, and E to Schedule 14A are also applicable
to
Schedule 14C."

   It would appear that additional disclosure consistent with
Items
11-14 of Schedule 14A is appropriate.

InfoByPhone, Inc.

2. Please expand the disclosure to include all material
information,
including audited financial statements and unaudited interim
period
financial statements, regarding InfoByPhone, Inc.

Ocean West Enterprises, Inc.

3. We note your statement at the end of the first paragraph of the
"To the stockholders..." letter that "In addition, the Board of
Directors of the Company has approved the spin off (sic) our
operating subsidiary Ocean West Enterprises, Inc. (the
"Subsidiary")."  Please expand the Information Statement
disclosure
regarding this spin off.  We may have further comment based upon
your
response.

IBP Private Equity Offering
4. Supplementally, please provide us with the IBP private equity
offering documents.
5. In addition, please provide us with details private equity
offering.
6. We note your statement that "As a result of such financing by
IBP
and its issuance of up to 6,666,666 shares of its common stock in
connection therewith, we will issue up to 6,666,666 additional
shares
of our common stock at the Closing to IBP stockholders which may
result in a total share exchange of 12,666,666 shares of common
stock
at Closing."  Please advise regarding the details of this
additional
transaction element.
7. We note your statement that "We believe that the Transaction
will
increase the total value of the Company to our investors."  Please
provide the basis for this statement, including but not limited
to,
pro forma financial statements, book value calculations, EPS
calculations, Discounted Cash Flow Analysis, and all other
material
valuation methodologies employed by the Board.  We may have
further
comment based upon your response.

Item 14. Mergers, Consolidations, Acquisitions and Similar
Matters-
Schedule 14A

8. Please expand your disclosure regarding the Transaction to
comply
with Item 14 of Schedule 14A.

Background of the Transaction
9. Please add a new section to the Information Statement regarding
the background of the Transaction.  Add details regarding the
chronology, individuals involved, management and director
involvement, negotiations, retention of professionals to assist in
transaction, and all other material background information.

The Boards` Reasons for Engaging in the Transaction

10. Please add a new subsection to the Information Statement
regarding the Board`s reasons for engaging in the Transaction.
Specifically identify all material factors considered by the Board
in
determining to engage in the transaction.  In addition, briefly
summarize the Board`s analysis of each material factor.  We may
have
further comment based upon your response.

Tax-free Reorganization

11. We note your statement that "The Transaction is expected to be
treated as a tax-free reorganization for federal income tax
purposes."  Supplementally, please identify the tax professional
that
is providing this tax opinion as well as providing us with a copy
of
that opinion.

Registration of up to 12,666,666 shares of common stock

12. We note that you may issue up to 12,666,666 shares of common
stock to IBP in the Transaction.  It would appear that these
shares
are unregistered and therefore restricted securities.  Please
advise
regarding this situation.  We may have further comment based upon
your response.

If you have any questions regarding these comments please call me
at
(202) 551-3417.

							Sincerely,

							Barry McCarty
							Senior Counsel

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