SecProbe.io

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                         International Development Corp.
                         534 Delaware Avenue, Suite 412
                             Buffalo, New York 14202
                               Tel. (416) 490-0254

                                 March 17, 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 AND FORM 10-KSB/A 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") will amend its Form 10-KSB/A
for  the  Fiscal  Year  Ended  August  31,  2004 to reflect any changes required
therein  as discussed below in response to your comments.  We would ask that you
review  our  replies to your comments and advise if we have adequately responded
to  your comments so that we may then file the amended Form 10-KSB/A  reflecting
these  changes.

FORM 10-KSB AND FORM 10-KSB/A FOR THE FISCAL YEAR ENDED AUGUST 31, 2004

ITEM 6. MANAGEMENT'S DISCUSSION AND ANALYSIS OR PLAN OF OPERATION

RESULTS OF OPERATIONS, P. 11

     1.   The  decrease  in  sales  revenue  in recent periods has been directly
          related  to  the  Company  focusing  on  the  reorganization  and
          repositioning  of  the  Corporation,  in  an effort to improve ongoing
          operations.  As  a  result  of  the recent reorganization, the Company
          believes  that  we  are  in  an improved position to take advantage of
          operational efficiencies and market growth opportunities. We have also
          reviewed  the Commission Guidance presented in Release No. 33-8350 and
          confirm  that  we  will  endeavor  in future filings to include a more
          comprehensive  analysis regarding any changes in our revenue accounts.

ITEM 8A.CONTROLS AND PROCEDURES, P. 13

     2.   We will amend the Company's August 31, 2004 Form 10-KSB/A filing under
          this  item  to  read  as  follows:

               Based  on  this evaluation, our chief executive officer and chief
               financial  officer  concluded  that  our  disclosure controls and
               procedures  are  effective to ensure that information required to
               be  disclosed  by  us in reports that we file or submit under the
               Exchange  Act  is  recorded,  processed,  summarized and reported
               within  the  time  periods  specified  in Securities and Exchange
               Commission  rules  and  forms,  except  for  the  management
               control/procedure  in relation to disclosures for future business
               operations,  which  resulted  in  the Company incorrectly stating
               that  it  had  terminated  its  water  purification business. The
               ineffective control was determined to be an isolated incident and
               had  an  immaterial  effect  on  the Company's Form 10-KSB Annual
               Report. Management has taken the necessary actions to revise this
               control  to  prevent  future  failures.

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FORM10-QSB FOR THE QUARTER ENDED NOVEMBER 30, 2004

BALANCE SHEETS, P.1

     3.   Due to the Company focusing on the reorganization and repositioning of
          the  Corporation,  in  an  effort  to  improve ongoing operations, the
          Company had no sales during the quarter ended 11/30/04. As a result of
          the  reorganization,  we  have  reorganized  our  water  purification
          business  into  a  new  subsidiary, have revised our testing and sales
          procedures for the water equipment, and are setting up a more reliable
          distribution system for this equipment, which Management believes will
          result  in  increased  product  sales,  along  with  the corresponding
          reduction  in  our  inventories,  as  Management intends to carry less
          inventory  on  hand  in  the future. All of the equipment currently in
          inventory  carries  a  full  ten-year  replacement  warranty  by  the
          manufacturer  from  the  date  of  installation.  As  a  result of the
          reorganization  of  the  Corporation  and the manufacturer's warranty,
          Management  is  confident  that  they can sell the remaining equipment
          units  that  are in the Inventory balance and that no excess inventory
          reserve  is  necessary  for  recording.

     4.   As of November 30, 2004 our outstanding net accounts receivable was 90
          days  old.  Based on past collection history and policy established by
          the  Company,  the  Company  provides  fully an allowance for doubtful
          accounts  for all accounts receivable after 180 days old or more. As a
          result  of  the  age  of  the receivables as of November 30, 2004, and
          Management's  analysis  of  collectibility,  no allowance for doubtful
          accounts  is  deemed  necessary  for  these  receivables.

          The Registrant hereby acknowledges the following:

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

-         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  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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