SecProbe.io

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                                Betty-Ann Harland
                         International Development Corp.
                         534 Delaware Avenue, Suite 412
                             Buffalo, New York 14202
                               Tel. (716) 332-7150

                                February 22, 2005

Mr. Ryan Rohn
Division of Corporation Finance
U.S. Securities and Exchange Commission
Washington, D.C.  20549

     RE:  INTERNATIONAL DEVELOPMENT CORP.
          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 Mr. Rohn:

     With  respect  to  the  above-captioned  matter,  please  be  advised  that
International  Development  Corp. (the "Registrant") has amended its Form 10-KSB
for the Fiscal Year Ended August 31, 2004 to reflect that the Registrant did not
terminate  its  water  purification business, but, rather, transferred its water
purification  business  to its wholly-owned subsidiary, Freshwater Technologies,
Inc.,  which  was  formed  on  January  21,  2005.  Although  the Registrant had
disclosed  its  intent  to  get  out  of  direct management of the water related
business  in  its  Form  10-KSB  for  the Fiscal Year Ended August 31, 2004, the
Registrant  ultimately  decided  that it could realize more value from the water
purification-related  assets  by  creating a wholly owned subsidiary to carry on
the  water  purification  business.

     Because  the  Registrant did not terminate the water purification business,
the  Registrant  did  not  file  a Form 8-K announcing such termination, and the
Registrant's  inventory  balance remained at the same level from August 31, 2004
to November 30, 2004.  Similarly, the Registrant did not address the termination
of  the  water  purification  business  in its Form 10-QSB for the Quarter Ended
November  30,  2004 because the business was never terminated by the Registrant,
but is currently being continued through its wholly-owned subsidiary, Freshwater
Technologies,  Inc.

     The  Registrant  hereby  acknowledges  the  following:

-    The  adequacy  and  accuracy  of  the  disclosure  in  the  filing  is  the
     responsibility  of  the  Registrant.

-    Staff  comment or changes in response to staff comment do not foreclose the
     Commission  from  taking  any  action  with  respect  to  the  filing;  and

-    The Registrant 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.

     Please  direct  any  questions  or  comments  about  this  letter  to  the
undersigned  at the address and telephone number indicated above, as well as the
Registrant's  attorney,  Norman  T.  Reynolds,  Esq. at 815 Walker Street, Suite
1250,  Houston,  Texas  77002,  telephone  (713)  237-3135.  Thank  you.

                                                  Very  Truly  Yours,

                                                  Betty-Ann Harland

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