SecProbe.io

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      February 4, 2005

Mail Stop 0510

By U.S. mail and facsimile to (416) 495-8625

Ms. Betty-Ann Harland
Chief Executive Officer
International Development Corp.
30 Denver Crescent, Suite 200
Toronto, Ontario, Canada  M2J 1G8

	RE:	Form 10-KSB for the Fiscal Year Ended August 31, 2004
		Form 10-QSB for the Quarter Ended November 30, 2004
			File No. 000-31343

Dear Ms. Harland:

		We have reviewed these filings and have the following
comments.  If you disagree with a comment, 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 respects.  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.

Form 10-KSB for the Fiscal Year Ended August 31, 2004

Item 1. Description of Business

1. We note your disclosure that you have elected to terminate the
water purification business and formulate a new business plan.
Please tell us the date that the Company committed to its plan to
terminate its water purification business and formulate a new
business plan.  Tell us why you have not filed an Item 2.05 Form
8-K
to announce your election to terminate the water purification
business and formulate a new business plan.

Form 10-QSB for the Quarter Ended November 30, 2004

Item 1. Financial Statements

Balance Sheet

2. We have noted that your inventory balance has not changed from
August 31, 2004 to November 30, 2004.  In consideration of your
decision to exit the water purification business, please explain
to
us your ability to sell this remaining inventory or why a full
excess
inventory reserve is not warranted.

Note E - Subsequent Events

3. We have noted that you have not disclosed any information
regarding your exiting the water purification business in your
Form
10-QSB.  Please amend this filing to disclose this information.
Refer to paragraph 20 of SFAS No. 146.

*    *    *    *

		Please respond to these comments within 10 business
days,
or tell us when you will provide us with a response.  Please file
the
amendment to your Form 10-QSB and provide us with a supplemental
response letter that keys your responses to our comments and
provides
any requested supplemental information.  Detailed letters greatly
facilitate our review.  Please file your supplemental response on
EDGAR as a correspondence file.  Please understand that we may
have
additional comments after reviewing your responses to our
comments.

      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.
Since the company and its management are in possession of all
facts
relating to a company`s disclosure, they are 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 their filings;
* staff comments or changes to disclosure 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 filing or in
response to our comments on your filing.

      If you have any questions regarding these comments, please
direct them to Ryan Rohn, Staff Accountant, at (202) 824-5525 or,
in
his absence, to Jeanne Baker, Assistant Chief Accountant at (202)
942-1835, or the undersigned at (202) 942-1798.

							Sincerely,

							John Hartz
							Senior Assistant Chief
Accountant

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Ms. Betty-Ann Harland
International Development Corp.
February 4, 2005
Page 3 of 3

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE

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